Systems And Methods For Identifying Compliance-Related Information Associated With Data Breach Events

ABSTRACT

Various examples are provided related to identification and management of compliance-related information associated with data breach events. In one example, a method includes receiving a first data file collection associated with a first data breach event; generating information associated with presence or absence of protected information elements of all or part of the first data file collection and incorporating data files including the protected information elements in a second data file collection; analyzing data files selected from the second data file collection; and incorporating the information associated with the analysis into machine learning information that may be used for subsequent analysis of data file collections.

CROSS-REFERENCE TO RELATED APPLICATIONS

This application claims priority to U.S. Provisional Application No.62/925,569, filed Oct. 24, 2019. This application is a continuation ofInternational Application No. PCT/US2020/057245, filed Oct. 24, 2020,which claims priority to U.S. Provisional Application No. 62/925,569,filed Oct. 24, 2019, both of which are hereby incorporated by referencein their entireties.

FIELD OF THE DISCLOSURE

The present disclosure relates to systems and methods for identificationand management of compliance-related information associated with databreach events.

BACKGROUND OF THE DISCLOSURE

According to Statista.com, in 2019, 1,473 data breaches were reported inthe United States, which exposed over 164.68 million sensitive records.In the first half of 2020, 540 data breaches were reported. As would beappreciated, a data breach occurs when a cybercriminal (a/k/a “hacker”)exfiltrates private data from a network, device, or system. This can bedone by the hacker's accessing of a computer or a device to expropriatestored thereon or by bypassing network security remotely to gain accessto the data files stored in or associated with the network. While mostreported data breaches can be attributed to hacking or malware attacksby third parties with nefarious intentions, other breaches can beattributed to insider leaks, payment card fraud, loss or theft of aphysical hard drive of files, and human error. Data breaches can bequite expensive to organizations that own or are responsible for thedata involved in the data breach event. Costs associated with addressingdata breaches typically include tangible costs related to regulatorycompliance (e.g., notification of affectedindividuals/organizations/regulatory agencies), remediation (e.g.,repairing/hardening the network, providing security to affectedindividuals/organization), and liability payments (e.g., damages paid toaffected individuals/organizations, penalties/penalties paid toregulatory agencies) investigation. Indirect costs (reputationaldamages, providing cyber security to victims of compromised data, etc.)often also result.

The subject matters of data files involved in data breaches will varyaccording to the business use case for the enterprise IT network that isbreached by the data hack. To this end, data breach events may beassociated with personal or company financial information such as creditcard or bank details, an individual's personal health information(“PHI”), an individual's personally identifiable information (“PII”), orintellectual property, among other things.

A familiar example of a data breach is when a hacker gains unauthorizedaccess into a corporate network and exfiltrates sensitive data out ofone or more databases accessible via the hacker's point of entry.However, not all breaches are associated with bad intent. If anunauthorized hospital employee views a patient's health information on acomputer screen over the shoulder of an authorized employee, that alsoconstitutes a data breach as defined by the regulatory frameworksassociated with private health information.

Data breaches can occur when employees use weak passwords, when knownsoftware errors are exploited and when computers and mobile devices thatare associated with a network are lost or stolen. Users' connections torogue wireless networks that capture login credentials or othersensitive information in transit can also lead to unauthorizedexposures. Social engineering—especially attacks carried out via emailphishing—can lead to users providing their login credentials directly toattackers or through subsequent malware infections. Criminals can thenuse the credentials they obtained to gain entry to sensitive systems andrecords—access which often can go undetected for months, or evenindefinitely. Threat actors can also target third-party businesspartners in order to gain access to large organizations; such incidentstypically involve hackers compromising less secure businesses to obtainaccess to the primary target on which networks valuable informationresides.

In the US, there is no comprehensive federal law that regulates therights of data owners and the attendant obligations of thoseorganizations or enterprises that are fully or partly responsible for adata breach. A wide variety of industry guidelines and governmentcompliance regulations mandate strict control of sensitive data typeswith a goal of preventing unauthorized access thereto that constitutes adata breach. Within a corporate environment, for example, the PaymentCard Industry Data Security Standard (“PCIDSS”) defines who may handleand use PII, such as credit card numbers when available in conjunctionwith the cardholders' names and addresses. Within a healthcareenvironment, the Health Insurance Portability and Accountability Act(“HIPAA”) regulates who may see and use PHI, such as a patient's name,date of birth, and healthcare diagnoses and treatments. There are alsospecific requirements for the reporting of data breaches via HIPAA—andits Health Information Technology for Economic and Clinical Health(HITECH) Act and Omnibus Rule—as well as the various state breachnotification laws. The consequences of intellectual property databreaches can lead to significant legal disputes, as well as businesslosses if the breach is made public.

In the absence of comprehensive US federal government regulation, manystates have enacted data breach notification laws that require bothprivate and public entities to notify individuals, whether customers,consumers or users, of breaches involving certain types of data, such asPII. The deadline to notify individuals affected by breaches can varyfrom state to state, and the specific notification requirements of eachjurisdiction can differ markedly, thus making it somewhat onerous forthose bearing compliance-related responsibilities associated with databreaches to meet their notification obligations. This is especially truesince most companies that are susceptible to data breaches engage ininternet commerce, which means that their customers should be consideredto be located in each of the 50 states. It follows that it may benecessary to perform individualized compliance activities for everystate and, as such, compliance with the various regulatory obligationsassociated with a single data breach event can be quite complex.Moreover, given the short time deadlines associated with some of thejurisdictions (e.g., Colorado and Florida have 30 day provisions), timeis of the essence in identifying those affected by a data breach anddetermining the nature and content of the data that may have beenassociated with the data breach.

In the US, the California Consumer Privacy Act (“CCPA”) came into effectin early 2020. This law is the most stringent in the US today and sincemany, if not most, companies that transact business in the US willlikely interact with California residents, the provisions of this laware of intense interest. Broadly, the CCPA gives consumers more controlover the personal information that businesses collect about them byproviding persons with a number of rights:

-   -   the right to know about the personal information a business        collects about them and how it is used and shared;    -   the right to delete personal information collected from them        (with some exceptions);    -   the right to opt-out of the sale of their personal information;        and    -   the right to non-discrimination for exercising their CCPA        rights.

The California Consumer Privacy Act (“CCPA”) (A.B. 375) is applicable tofor-profit businesses that collect and control California residents'personal information, do business in the state of California, and meetat least one of the following thresholds:

-   -   Annual gross revenues larger than $25 million;    -   Receive or disclose the personal information of 50,000 or more        California residents, households, or devices each year; or    -   Make 50 percent or greater annual revenue from selling        California residents' personal information.

Outside of the US, other various regulatory frameworks exist for dataprotection and deadlines for notification of affected persons, as wellas for penalties for non-compliance with data privacy mandates. The mostwell-known, and likely the one of the most important in this modernworld of global commerce, is the European Union General Data ProtectionRegulation (“GDPR”). The GDPR not only applies to organizations locatedwithin the EU but also applies to organizations located outside of theEU if they offer goods or services to, or monitor the behavior of, EUdata subjects, that is, persons. In addition to data breachnotifications, organizations that collect personal data from individualsmust take affirmative steps to ensure that internal checks are placed onaccess to private information. Thus, GDPR requires internal audits toensure that only authorized persons are allowed to access privateinformation.

Notification requirements of the GDPR are strict. Companies are requiredcompanies to notify all data subjects that a security breach hasoccurred within 72 hours of first discovery of the breach. The method ofthis notification includes as many forms as deemed necessary todisseminate the information in a timely manner, including email,telephone message, and public announcement. This requires immediateaction to process the scope and content of the data breach by anenterprise that discovers that a data breach has occurred. Penalties fornon-compliance with the GDPR can be severe: enterprises found to be inviolation of the provisions of the GDPR can be fined up to 4% of annualglobal turnover or 20 Million Euros, whichever is greater. Otherviolations are assessed on a tiered basis depending on the infraction.For example, a company can be fined 2% for not having its records inorder, not notifying the supervising authority and the data subjectabout a security breach in a timely manner, or for not conducting arequired impact assessment of a security breach.

While it may at first not seem to be a difficult problem to provide therequired notifications to affected persons after a data breachnotification, in practice, the task is daunting in most situations.Since most data breach events involve large numbers of data files andtime periods for notification can be short in relevantlocations/jurisdictions (e.g., EU, Colorado, Florida), time willnonetheless be of the essence even while the tasks required forcompliance may be complex. The amount of information that must bereviewed after a data breach notification can be expansive. For example,during a routine audit, an enterprise IT network administrator candetermine that an unauthorized forwarding rule was unknowingly appliedthree years previously and that that five employee mailboxes werecompromised for that entire time. Compliance with applicable laws,rules, regulations, policies, or contractual obligations will require ahuman review team, for example an outside law firm, to determine thenature of the compromised data in order to provide the necessarynotifications to affected parties and regulatory bodies, as well as todetermine potential liability for the breach.

Review of data involved in data breach events has largely remained amanual task for human reviewers because the vast majority of data—someestimates say 80%—maintained in businesses today comprises some form ofunstructured data (e.g., documents, spreadsheets, emails, presentations,audio and video, web searches, images, and social media posts,handwritten notes) that does not readily lend itself to accurateautomated review and identification using prior art methodologies. Ofcourse, unstructured data is just as likely to include or be associatedwith personally identifiable information or other regulated informationtypes that are protected from unauthorized disclosure in context. Thus,the insights and intelligence of humans has been required to conductmeaningful and suitably accurate review of such information in order toensure that each data file is examined in the context of complianceobligations.

To this end, existing methods used to identify the scope and content ofa data breach typically involves a team of human reviewers who eachindividually review a subset of the overall dataset of interest. Eachperson will create an individual database (e.g., a spreadsheet). Whilethe review team can be provided with guidelines as to the subject matterof the review and the form of the database preparation, in practice,each reviewer will introduce subjectivity into their databasepreparation. This can, in turn, lead to missed information that willnever be included in the final work product, which can give rise toliability if an audit reveals such mistakes. Even assuming that thehuman reviewers' work is substantially free of errors, current methodsrequire manual data entry by the reviewers to create each individualspreadsheet. Each reviewer will have her own way of assessing the data,especially when relevant data may occur in different forms in differentdatasets. When the review of the entire dataset that is the subject ofthe data breach event is completely reviewed, a Quality Assurance (“QA”)person or group of individuals must perform the task of merging eachindividual database to remove duplicate individuals and to ensure theentered data is correct. In many cases, the task of generating acompliance-related database within the mandated deadlines cannot be meteven with a large team of human reviewers.

While it might be expected that some of the data review could beautomated in order to accelerate the review, in practice, this has notbeen possible for a number of reasons. First, the laws and regulationsmay not include “safe harbor” provisions that will excuse missednotifications. Rather, the laws and regulations are generally based onthe understanding that every individual affected by a data breach mayexperience harm from that breach. If a person is not identified, or ifnot all of the breached information is identified for that person, theperson will not be able to take affirmative steps to protect herself andthat person may not be included in any remedies provided to affectedparties. Existing data review methodologies are not able toautomatically process the wide variety of data that may be present indata breach events, especially since much of the data generated in eachorganization will be “bespoke” or “customized” to the use cases andaccording to the preferences of businesses or that of individualemployees. Moreover, many of the data files in a data breach event willbe in forms that are not readily processable by automated documentreview systems. In this regard, image data may contain PII, such asdriver's licenses images that are acquired as customer identification.When such image data files are included in a data breach event, thepersons whose driver's license is included in the breached data files,which will include a plurality of elements of personal data (i.e., fullname, driver's license number, date of birth, sex, height, and address)will have to be notified by the network owner or manager of thedisclosure of her data.

Of course, the person cannot be notified of the data breach until allrelevant data is identified and manually entered into a database whereall information belonging to her is linked as a group. If there is alarge number of image files in the database, the amount of staffingand/or time needed to review the files and to manually extract and linkall of the relevant information can exceed the deadlines set out fornotification of the breach, especially when short notification times aremandated. For example, it could be physically impossible to marshal theresources needed to comply with the notification deadlines mandated bythe GDPR of 72 hours from notification of the breach. Even with longerturnaround times for notification, the sheer amount of data that needsto be reviewed, identified, and linked can make error-free notificationdatabase preparation difficult, if not impossible using manual reviewmethods that integrate the work product of multiple human reviewers. Andsince error-free notifications are required, current methodologiescannot allow compliance with notification rules to be ensured.

There remains a need for improvements in the ability to preparecompliance-related databases associated with notifications of partiesaffected by a data breach as are required by one or more laws, rules,regulations, policies, or contractual obligations. The presentdisclosure provides these and other benefits.

SUMMARY OF THE DISCLOSURE

Aspects of the present disclosure are related to identification andmanagement of compliance-related information associated with data breachevents. In one aspect, among others, a method of managingcompliance-related activities after a data breach associated with anenterprise IT network comprises receiving, by at least one computer, afirst data file collection associated with a first data breach event.The first data file collection can be generated by analysis of the firstdata breach event and derived from a bulk data file collection stored onor associated with a first enterprise IT network of interest formonitoring for an occurrence of data breach events; the first data filecollection can comprise at least some of structured, unstructured, andsemi-structured data file types; and at least some of the first datafile collection can comprise protected information havingcompliance-related activities associated therewith. The method furthercomprises generating, by the at least one computer, informationassociated with presence or absence of protected information elements ofall or part of the first data file collection and, if the generatedinformation indicates that a data file in the first data file collectionincludes the protected information elements, incorporating that datafile in a second data file collection; analyzing, by at least one humanreviewer, a subset of individual data files selected from the seconddata file collection to validate that each data file in the subset ofindividual data files comprises one or more of the protected informationelements; and incorporating, by the at least one computer, theinformation associated with the analysis of the subset of individualdata files into machine learning information configured for subsequentanalysis of either or both of the first and second data filecollections. If it is determined that the one or more protectedinformation elements are not present in a data file, that data file canbe removed, by the at least one human reviewer, from the second datafile collection and re-incorporating that data file into the first datafile collection; or if it is determined that the one or more protectedinformation elements are present in a data file: at least one entityidentification can be derived, by either or both of the at least onehuman reviewer or the at least one computer, for an entity associatedwith each of the one or more protected information elements in that datafile, wherein the entity comprises an individual, a group ofindividuals, an organization, or a company; and information associatedwith each of the one or more protected information elements and theassociated entity can be generated by either or both of the at least onehuman reviewer or the at least one computer.

In various aspects, the unstructured data file type in the first datafile collection can comprise image files. The method can furthercomprise selecting, by the at least one computer, a subset of imagefiles from either or both of the first and second data file collections;configuring, by the at least one computer, the subset of image files fordisplay and selection on a user device associated with the at least onehuman reviewer; displaying, by the at least one computer, a plurality ofthe image files from the subset of image files on the user device;selecting, by the at least one human reviewer, a displayed image whenthe at least one human reviewer identifies that the displayed image isassociated with the one or more protected information elements; andrecording, by the at least one computer, information associated with theat least one human reviewer's selection of the displayed image, therebyproviding identification information for the presence or absence of theone or more protected information elements in at least some image filesin the subset of image files selected from either or both of the firstand second data file collections. The method can further compriseincorporating, by the at least one computer, the identificationinformation into machine learning training information; and analyzing,by the at least one computer, image files in the first and second datafile collections for the presence of the one or more protectedinformation elements.

In one or more aspects, the method can further comprise identifying, bythe at least one computer, some or all of the one or more protectedinformation elements and the at least one entity identification in theimage files; and extracting, by the at least one computer, theidentified protected information elements and the at least one entityidentification from the image files for incorporation in a database. Themethod can further comprise recording, by the at least one computer,information associated with the analysis by the at least one humanreviewer of each of the subset of individual data files in the secondcollection of data files; and incorporating, by the at least onecomputer, the at least one human reviewer's analysis information astraining information for use in subsequent analysis of one or more of:data files in the first data file collection; data files in the seconddata file collection that are not included in the subset of individualdata files; data files in the subset of individual data files that havenot yet been reviewed by the at least one human reviewer; a third datafile collection derived from a bulk data file collection stored on orassociated with the first enterprise IT network, wherein the third datafile collection is generated after a second data breach event associatedwith the first enterprise IT network; or a fourth data file collectionderived from a bulk data file collection stored on or associated with asecond enterprise IT network that is different from the first enterpriseIT network, wherein the fourth data file collection is generated after adata breach event occurring on the second enterprise IT network.

In some aspects, the method can further comprise determining, by the atleast one computer, whether one or more second collection data files ofthe second data file collection are associated with the at least oneidentified entity and, if other second collection data files areassociated with that identified entity, generating linkages between theentity-associated files, thereby providing a linked data file collectionlinked with one or more entity identifications having the one or moreprotected information elements associated therewith. Each of the seconddata file collection can be arranged for display and selection on adisplay device associated with the at least one human reviewer as one ormore of: a plurality of defined categories of the protected informationelements; a count of data files comprising the protected informationelements; and a count of data file categories comprising the protectedinformation elements. The method can further comprise displaying, by theat least one computer, text summaries extracted from a data file in thesecond data file collection on a device display of the at least onehuman reviewer; selecting, by the at least one human reviewer, some orall of the highlighted protected information elements and entityidentifications, thereby providing human reviewer validation of theprotected information elements and entity identifications in the datafile; and adding, by the at least one computer, the selected protectedinformation elements and entity identifications to the database. Thedisplayed text summaries can comprise each of a protected informationelement and an entity identification in the data file; the textsummaries can each be provided on the display with highlightinggenerated by the at least one computer; and the text summaries can beconfigured to allow the at least one human reviewer to select all orpart of each of the protected information element and entityidentification.

In various aspects, when the second data file collection is identifiedby either or both of the at least one human reviewer or the at least onecomputer as comprising a plurality of protected information elementsassociated with one or more entity identifications, each of theplurality of protected information elements can be linked to each of theone more entity identifications. The second data file collection cancomprise an unstructured data file and the plurality of protectedinformation data elements associated with the one or more entityidentifications are included as tabular data in the unstructured datafile. The identification of protected information in the first data filecollection can be associated with a generated confidence level. When adetermination that a data file in the first data file collection meetsor exceeds the generated confidence level, that data file can beincluded in the second data file collection. The compliance-relatedactivities can be defined by one or more of laws, regulations, policies,procedures, and contractual obligations associated with the protectedinformation. The compliance-related activities can comprise one or moreof: notifying, by the at least one computer or by a manager of the firstenterprise IT network, each identified entity of the protectedinformation associated with that entity that was involved with the firstdata breach event; and notifying, by the at least one computer or thefirst enterprise IT network manager, a regulatory authority of the firstnetwork breach event and providing the regulatory authority withinformation associated with the identified entities having the protectedinformation involved in the first data breach event.

In another aspects, a method of managing compliance-related activitiesafter a data breach associated with an enterprise IT network comprisesproviding, by at least one computer, a machine learning library;receiving, by at least one computer, a third data file collectionassociated with a second data breach event; and analyzing, by the atleast one computer, the data files in the third data file collection togenerate a compliance-related database configured for providingnotifications associated with the second data breach event. The machinelearning library can be generated by receiving, by the at least onecomputer, a first data file collection associated with a first databreach event; generating, by the at least one computer, informationassociated with presence or absence of protected information elements ofall or part of the first data file collection and, if the generatedinformation indicates that a data file in the first data file collectionincludes the protected information elements, incorporating that datafile in a second data file collection; analyzing, by at least one humanreviewer, a subset of individual data files selected from the seconddata file collection to validate that each data file in the subset ofindividual data files comprises one or more of the protected informationelements; and incorporating, by the at least one computer, theinformation associated with the analysis of the subset of individualdata files into machine learning information configured for subsequentanalysis of either or both of the first and second data filecollections, the machine learning information stored in the machinelearning library. The first data file collection can be generated byanalysis of the first data breach event and derived from a bulk datafile collection stored on or associated with a first enterprise ITnetwork of interest for monitoring for an occurrence of data breachevents; the first data file collection comprises at least some ofstructured, unstructured, and semi-structured data file types; and atleast some of the first data file collection comprises protectedinformation having compliance-related activities associated therewith.If it is determined that the one or more protected information elementsare not present in a data file, that data file can be removed, by the atleast one human reviewer, from the second data file collection andre-incorporating that data file into the first data file collection; orif it is determined that the one or more protected information elementsare present in a data file: at least one entity identification can bederived, by either or both of the at least one human reviewer or the atleast one computer, for an entity associated with each of the one ormore protected information elements in that data file, wherein theentity comprises an individual, a group of individuals, an organization,or a company; and information associated with each of the one or moreprotected information elements and the associated entity can begenerated by either or both of the at least one human reviewer or the atleast one computer.

In one or more aspects, the method can further comprise incorporating atleast some human reviewer analysis with the third data file collectionanalysis. The third data file collection analysis can includeidentification of the presence or absence of protected informationelements in the data files. At least some of the data files in the thirddata file collection can comprise one or more protected informationelements, and the method can further comprise linking, by the at leastone computer, some or all of the one or more protected informationelements with at least one entity, thereby generating entityidentification information linkage information for at least some of theprotected information elements in the data files. At least some of thedata file types in the third data file collection can comprise imagefiles. The third data file collection can comprise at least someunstructured data files and a plurality of protected informationelements associated with the one or more entity identifications can beincluded as tabular data in the unstructured data file. Thecompliance-related activities can be defined by one or more of laws,regulations, policies, procedures, and contractual obligationsassociated with the protected information.

Additional advantages of the disclosure will be set forth in part in thedescription that follows, and in part will be apparent from thedescription, or may be learned by practice of the disclosure. Theadvantages of the disclosure will be realized and attained by means ofthe elements and combination particularly pointed out in the appendedclaims. It is to be understood that both the foregoing generaldescription and the following detailed description are exemplary andexplanatory only and are not restrictive of the disclosure, as claimed.

BRIEF DESCRIPTION OF THE DRAWINGS

FIGS. 1A and 1B are flow charts illustrating examples of identificationand management of compliance-related activities after a data breachassociated with an enterprise IT network, in accordance with variousimplementations of the present disclosure.

FIG. 2 is a block diagram illustrating an example of a system forimplementing the management of the compliance-related activities, inaccordance with various implementations of the present disclosure.

FIGS. 3A-3M illustrate examples of user interfaces implemented by thesystem for management of the compliance-related activities, inaccordance with various implementations of the present disclosure.

FIG. 4 is a block diagram illustrating examples of hardware componentsof the system, in accordance with various implementations of the presentdisclosure.

DETAILED DESCRIPTION OF THE DISCLOSURE

In the following detailed description, reference is made to theaccompanying drawings, which form a part hereof, and within which areshown by way of illustration certain aspects by which the subject matterof this disclosure may be practiced. It is to be understood that otheraspects may be utilized, and structural changes may be made, withoutdeparting from the scope of the disclosure. In other words, illustrativeaspects and aspects are described below. But it will of course beappreciated that in the development of any such actual implementation,numerous implementation-specific decisions must be made to achievespecific goals, such as compliance with system-related andbusiness-related constraints, which may vary from one implementation toanother. Moreover, it will be appreciated that such development effortmight be complex and time-consuming but would nevertheless be a routineundertaking for those of ordinary skill in the art having the benefit ofthis disclosure.

Unless defined otherwise, all technical and scientific terms used hereinhave the same meaning as is commonly understood by one of ordinary skillin the art to which this disclosure belongs. In the event that there isa plurality of definitions for a term herein, those in this sectionprevail unless stated otherwise.

Wherever the phrases “for example,” “such as,” “including” and the likeare used herein, the phrase “and without limitation” is understood tofollow unless explicitly stated otherwise.

The terms “comprising” and “including” and “involving” (and similarly“comprises” and “includes” and “involves”) are used interchangeably andmean the same thing. Specifically, each of the terms is definedconsistent with the common patent law definition of “comprising” and istherefore interpreted to be an open term meaning “at least thefollowing” and is also interpreted not to exclude additional features,limitations, aspects, etc.

The term “about” is meant to account for variations due to experimentalerror. All measurements or numbers are implicitly understood to bemodified by the word about, even if the measurement or number is notexplicitly modified by the word about.

The term “substantially” (or alternatively “effectively”) is meant topermit deviations from the descriptive term that do not negativelyimpact the intended purpose. Descriptive terms are implicitly understoodto be modified by the word substantially, even if the term is notexplicitly modified by the word “substantially.”

An “enterprise IT network” means the components required for theexistence, operation and management of an enterprise IT environment,which can be internal to an organization and deployed within ownedfacilities, such as in an internal corporate IT network. An “enterpriseIT network” can also be deployed within a cloud computing system. Stillfurther, an “enterprise IT network” can comprise both internal networksand cloud computing systems, as is increasingly common today. An“enterprise IT network” can also include remote devices (e.g., laptops,cellular phones, medical devices, Internet of Things (“IoT”) devices)that are in communications engagement with either or both of an internalIT network or an enterprise cloud computing network.

An “enterprise” can include a company, an organization, a person, orcollections thereof. For example, an individual herself can be an“enterprise” (e.g., a doctor in a solo practice), a group of individualswho together form an organization can be an “enterprise” (e.g., a groupof doctors in a medical practice), or a group of organizations cantogether form an “enterprise” (e.g., a group of medical practices thatshare patient data with each other).

As used herein, “managed data” comprises data that is stored on orassociated with a specific enterprise IT network. It is “managed”because such data is under the control or supervision of an enterpriseIT department having obligations to maintain the operation and securityof such data. The type of managed data contemplated for operation in thesystems and methods of the present disclosure are expansive. Classes ofmanaged data can comprise each of “structured data,” “unstructureddata,” and “semi-structured data, as such terms are defined anddescribed in detail hereafter. The forms of managed data will berelevant in the context of the subject enterprise IT network and thebusiness operations conducted by an authorized user of the subjectmanaged data. As would be appreciated, modern business operationstypically employ a wide variety of data types in the usual course ofoperations including, but not limited to: documents, emails, websites,chat logs, videos, audio recordings, PDFs, and texts, among others.

“Protected information” is a subset of “managed data.” “Protectedinformation” comprises any information included in the managed data thatis associated with one or more of laws, regulations, policies,procedures, or contractual obligations that define protections andaccess limitations to the subject matter/content of the respective datafiles.

To this end, “protected information” can comprise one or more of“personal data” or “personally identifiable information” (“PII”) orequivalents thereof as defined in one or more national, state, or locallaws that are relevant to a subject data breach. Examples of such lawsinclude:

-   -   Gramm-Leach-Bliley Act (GLBA): U.S. financial institutions must        disclose how they share customers' information;    -   Health Insurance Portability and Accountability Act (HIPAA):        U.S. health providers must take adequate steps to protect        patients' PHI;    -   Family Educational Rights and Privacy Act (FERPA): U.S.        educational institutions must have the consent of students over        18 years old to release records such as schedules, transcripts,        and disciplinary information;    -   Health Information Technology for Economic and Clinical Health        (HITECH): Organizations regulated by HIPAA must report data        breaches affecting more than 500 people to the affected        individuals, the U.S. Department of Health and Human Services,        and the media;    -   California Consumer Privacy Act of 2018 (A.B. 375): provides        consumers with certain rights to the use and control of their        personal information;    -   Colorado Data Protection Statute (Colo. Rev. Stat. § 6-1-716):        applies to an individual or commercial entity that conducts        business in CO and that owns, licenses, or maintains        computerized data that includes personal information as defined        in the statute;    -   EU General Data Protection Regulation (“GDPR”): Regulates the        processing of personal data of European citizens. It applies to        organizations both inside and outside the European Union (EU)        that process personal data of EU citizens; or    -   Australian Privacy Act “APA”: Regulates the use of information        of Australian citizens.

The actual identity of what an owner or manager of an enterprise ITnetwork must identify for notification of a data breach to an affectedindividual will vary according to the applicable laws, regulations,rules, and policies and the definitions therein. For example, the GDPRapplies to “personal data,” defined as any data that relates to anidentified or identifiable natural person (a living individual), whereasthe APA applies to “personal information,” which is defined asinformation or opinion about an identified individual or informationthat makes an individual identifiable. While these respective privacylaws might appear similar, “data” and “information” are two differentthings. Data is raw information, the basis for things like statistics.Information, on the other hand, is the end result, taking thosestatistics and declaring the findings. The GDPR requires businesses todeclare what they do with that raw information. APA, on the other hand,focuses on information used to directly identify an individual. Itfollows that each of the data breach notification laws associated witheach of these regulations are also related to notifying affectedindividuals of what data was disclosed (GDPR) versus what information(APA) about them was disclosed in the subject breach.

“Protected information” can also be subject to access or control rulesas defined by one or more agency regulations or by one or morestandard-setting organizations. Examples of such standards include:

-   -   Payment Card Industry Data Security Standard (PCI DSS):        Companies that process credit card information must protect this        data and conduct transactions within a secure network.    -   Ethical rules governing information disclosure as set out by        medical associations, bar associations, religious organizations,        etc.

The class of protected information that is defined as “PII” comprisesany representation of information that permits or facilitates thegeneration of the identity of an individual to whom the informationapplies to be reasonably inferred by either direct or indirect means.Such inference of identity can be determined by data analysis techniquesthat exist today and/or as will be developed in the future. In someimplementations, PII is defined as information: (i) that directlyidentifies an individual (e.g., name, address, social security number orother identifying number or code, telephone number, email address, etc.)or (ii) by which can be used to indirectly identify a specificindividual in association with other data elements, i.e., indirectidentification. Such data elements may include a combination of gender,race, birth date, geographic indicator, and other descriptors).Additionally, information permitting the physical or online contactingof a specific individual also comprises”

“Protected health information” (“PHI”) as used herein is the term givento health data created, received, stored, or transmitted byHIPAA-covered entities and their business associates in relation to theprovision of healthcare, healthcare operations and payment forhealthcare services. PHI includes all individually identifiable healthinformation, including demographic data, medical histories, testresults, insurance information, and other information used to identify apatient or provide healthcare services or health care coverage. In thecontext of US law, “protected” means the subject information isprotected under the HIPAA Privacy Rule. A further classification of PHIis “Personally Identifiable Health Information,” (“PIHA”) which issubstantially co-extensive with many of the data elements that comprise“PII.” PIHA includes:

-   -   Names (Full name or last name and initial)    -   All geographical identifiers smaller than a state, except for        the initial three digits of a zip code if, according to the        current publicly available data from the U.S. Bureau of the        Census: the geographic unit formed by combining all zip codes        with the same three initial digits contains more than 20,000        people: and the initial three digits of a zip code for all such        geographic units containing 20,000 or fewer people is changed to        000    -   Dates (other than year) directly related to an individual    -   Phone Numbers    -   Fax numbers    -   Email addresses    -   Social Security numbers    -   Medical record numbers    -   Health insurance beneficiary numbers    -   Account numbers    -   Certificate/license numbers    -   Vehicle identifiers (including serial numbers and license plate        numbers)    -   Device identifiers and serial numbers,    -   Web Uniform Resource Locators (URLs)    -   Internet Protocol (IP) address numbers    -   Biometric identifiers, including finger, retinal and voice        prints    -   Full face photographic images and any comparable images    -   Any other unique identifying number, characteristic, or code        except the unique code assigned by the investigator to code the        data

“Protected information” in accordance with the disclosure also includes“sensitive personal information,” which is data consisting of racial orethnic origin, political opinions, religious or philosophical beliefs,trade union membership, genetic data, biometric data, data concerninghealth or data concerning a natural person's sex life or sexualorientation.

“Protected information” as used herein can also comprise informationthat is subject to one or more contractual obligations that limit orprevent the disclosure of the information as described in the subjectcontract(s). Identification of such protected information can be viareview of the contracts and aligning the subject matter set out in thecontracts with a collection of information present in the managed data.For example, key words associated with the subject matter of thecontractual obligations can be relevant to defining such protectedinformation.

Further, “protected information” can be defined in the context ofapplicable laws, regulations, rules, and policies having such aninformation type or content that is of interest for maintenance of theconfidentiality thereof. In this regard, “protected information” can beobtained from a definition incorporated in applicable laws, regulations,rules, policies, and contractual obligations that are applicable incontext.

In further contexts, protected information can comprise information thatis relevant in context for a company, organization, etc. that has valuedue to its not being generally known and for which reasonable steps aretaken to prevent its disclosure such that it can comprise “sensitivebusiness information.” For example, “sensitive business information” isinformation that would pose a business or financial risk to its owner ora third party if unintentionally released to a competitor or the generalpublic.

As will be appreciated, not all managed data will comprise “protectedinformation” in that not all data accessed in a data breach event willbe relevant to laws, rules, regulations, policies, or contractualobligations associated with compliance-related activities, as definedelsewhere herein. The types of managed data that comprises “protectedinformation” in the systems and methods herein will nonetheless berecognized as being expansive. The protected information can also beidentified by a company or organization as being undesirable forunauthorized disclosure to identified persons, groups, or companies,such as when such unauthorized disclosure may cause loss or reduction invalue of intellectual property, financial harm, or reputational damageto the owner of the subject protected information.

When protected information is included in managed data affected by adata breach event, actual or potential disclosure of the protectedinformation is possible. As such, upon notification of a data breach inan enterprise IT network that includes protected information, themanager of such network will generally be required to undertake one ormore compliance-related activities as defined by laws, rules,regulations, policies, or contractual obligations associated with thesubject protected information. A necessary first step in ensuringcompliance with the laws, rules, procedures, policies, and contractualobligations that may be associated with protected information is theneed to identify what protected information is present in the breacheddata files in the first order, and to align or link the identifiedprotected information with an entity to which the protected informationis associated.

Yet further, for compliance-related activities, such as notificationsrequired under one or more applicable laws, rules, regulations,policies, or contractual obligations, the data elements that willcomprise “protected information” that are relevant for identification inrelation to a data breach event may differ in context.

For example, as defined under the GDPR, “personal information” (whichis, by definition, “protected information” herein on account of itsregulation under the GDPR) is defined as: any information relating to anidentified or identifiable natural person (‘data subject’); anidentifiable natural person is one who can be identified, directly orindirectly, in particular by reference to an identifier such as a name,an identification number, location data, an online identifier or to oneor more factors specific to the physical, physiological, genetic,mental, economic, cultural or social identity of that natural person.

Under the CCPA, “personal information” is information that identifies,relates to, or could reasonably be linked with an individual or theindividual's household. The statute provides a non-exhaustive list ofpersonal information:

-   -   Identifiers including real name, alias, postal address, unique        personal identifier, online identifier, internet protocol (IP)        address, email address, account name, social security number,        driver's license number, passport number, or other similar        identifiers;    -   Characteristics of protected classifications under California or        federal law;    -   Commercial information, including records of personal property,        products, or services purchased, obtained, or considered, or        other purchasing or consuming histories or tendencies;    -   Biometric information;    -   Internet or other electronic network activity information,        including, but not limited to, browsing history, search history,        and information regarding a consumer's interaction with an        internet website, application, or advertisement;    -   Geolocation data;    -   Audio, electronic, visual, thermal, olfactory, or similar        information;    -   Professional or employment-related information; and    -   Education information, defined as information that is not        publicly available personally identifiable information as        defined in the Family Educational Rights and Privacy Act        (FERPA).

The CCPA statutory definition also includes inferences from personalinformation used to create a profile about a consumer that would reflectthe person's preferences, characteristics, psychological trends,predispositions, behavior, attitudes, intelligence, abilities, andaptitudes. It will be appreciated that such inferences are similar tothose defined as “sensitive personal information,” as are defined inother contexts.

Under the Colorado Data Protection Statute (Colo. Rev. Stat. § 6-1-716),“personal information,” (which is, by definition, is “protectedinformation” due to its regulation under this statute) is defined as:

-   -   (a) a CO resident's first name or first initial and last name in        combination with any one or more of the following data elements        that relate to the resident, when the data elements are not        encrypted, redacted, or secured by any other method rendering        the name or the element unreadable or unusable:        -   Social Security number;        -   Student, military, or passport ID number;        -   Driver's license number or other identification card number;        -   Medical information;        -   Health insurance identification number; or        -   Biometric data;    -   (b) Usemame or email address, in combination with a password or        security question that would permit access to an online account;        or    -   (c) Account number or credit card number or debit card number in        combination with any required security code, access code, or        password that would permit access to that account.

The above descriptions of each of the GDPR, CCPA, and Colorado DataProtection Statute are provided as non-limiting examples, only. Asdiscussed herein, the various obligations, relevant informationelements, and notification requirements will depend on the one or morelaws, regulations, rules, policies, or contractual obligations that areat issue or that are relevant to a data breach event.

In some implementations, performance of compliance-related activitiesassociated with a data breach event will incorporate the specificnotification requirements of one or more applicable laws, rules,regulations, policies, or contractual obligations. Since the amount ofreview and processing needed to identify personal data and PII is likelysubstantially equivalent using in most data breach review scenarios, thesystem can be configured to search for and identify personal dataelements. Therefore any identification of “protected information” thatis associated with an individual can be conducted to identify suchindividual's personal data elements. Thus, in an implementation, thesearch can be configured to identify “personal data elements” for anindividual as set out in the GDPR or for “personal information” asdefined by the CCPA. Any compliance-related activities, such asnotifications of affected individuals that includes an inventory ofprotected information that was a subject of the data breach event, canbe configured to align with the specific requirements of each of theapplicable laws, rules, regulations, policies, or contractualobligations. For example, a notification to an affected individual caninclude all of the information required under Colorado law but no more,which may be less than that required to comply with the CCPA or theGDPR. For the APA, the identified personal data can be configured in anotification to the affected person in the form of information, asrequired thereunder. In this regard, an identified disclosure of aperson's address could be in the form of “your address” to comply withdata identifications under the GDPR, in the form of “postal address”under the CCPA, and in the form of “where you live” for the APA.

Because managed data that comprises protected information will besubject to one or more laws, regulations, rules, policies, orcontractual obligations associated with access thereto, managers ofenterprise IT networks with which the protected information isassociated must be able to not only detect when unauthorized access tosuch protected information—that is, a “data breach”—has been attemptedand successfully achieved, these managers must also be able to suitablyundertake the relevant compliance-related activities necessary toaddress the legally mandated and/or business appropriate activities thatexist as a consequence of an IT enterprise becoming aware of the databreach.

A “data breach” is thus an event involving at least part of anenterprise IT network where managed data (as defined elsewhere herein)is stored or maintained in one or more databases operational with the ITinfrastructure or that is stored on one or more on one or more devicesin communications engagement therewith, is accessed, copied,transmitted, viewed, or used by one or more persons, devices, or systemsthat do not have authorization to do so, where such authorization iscreated (or prevented) by one or more laws, regulations, policies,rules, or contractual obligations generated or determined by governmentauthorities, regulatory agencies, standards setting organizations,business associates or individuals having at least some authority tocontrol access to or to manage the use of the subject protectedinformation.

A data breach can originate from outside of an enterprise associatedwith the managed data files. For example, a person or organization withnefarious intent (e.g., a hacker, a foreign government, etc.) can seekunauthorized access to the managed data that may comprise protectedinformation to further their own interests.

A data breach can also originate from inside of an enterprise when aperson having authorized access to the managed data comprising protectedinformation expropriates such data for their own unauthorized purposes.For example, a bank employee who has authorized access to customerpersonal and financial data for the purpose of doing her job candownload the protected information to open credit accounts for herself.

A data breach does not have to involve intentional bad acts, however. Tothis end, a data breach can occur when protected information isimproperly accessed or handled within an organization in ways that donot comply with laws, regulations, rules, policies, or contractualobligations generated for or associated with the subject managed data.For example, an employee who is transferred to another department in acompany may retain access to databases that contain protectedinformation that are no longer relevant to the roles andresponsibilities of her current job. If this employee previously workedin the company's human resources department, but now works in facilitiesmanagement, continued access to her fellow employee's personalinformation may rise to the level of a data breach in some contexts. Asmentioned previously, depending on the regulatory framework associatedwith a type of protected information, allowing an unauthorized person toview protected information may rise to the level of a data breach, evenif the person did not actually view the subject information.

A data breach can also occur when a device (e.g., a computer, laptop,cellular phone, internet enabled device, etc.) has been lost or stolensuch that managed data that comprises protected information that isstored thereon may be accessed, copied, or used by a person, device, orsystem, that does not have authorization to do so and whereby suchactivities would be out of compliance with one or more applicable laws,regulations, rules, policies, or contractual obligations associated withsuch protected information.

A “data breach event notification” can be generated when informationabout the occurrence of a data breach is received by a manager of theenterprise IT network, such as automatically from a computernotification (e.g. via a network security application operational on themanaged network) and/or from a human (e.g., user, employee, third party,law enforcement officer, etc.) that one or more systems, applications,devices, persons, organizations etc. has acquired, or has potentiallyacquired, access to managed data operational within the enterprise ITnetwork. A data breach event notification can also be generated whenunauthorized access to the managed data is attempted but not achieved,when it is at least possible that out of compliance access to theprotected information may have been attained. A data breach eventnotification can also be generated when out of compliance access to themanaged data operational on the enterprise IT network may have occurred,but it is not presently known whether such access in fact occurred.

A data breach event notification can also provide information relevantto a data breach event while events are underway, such as when all orpart of an enterprise IT network is being subjected to an attack from anexternal source (e.g., attempted or actual access to files from anunauthorized external server/network) or from abnormal activity detectedfrom within the network (e.g., unusual downloading or forwardingactivity). Such data breach event notifications can be generated byintrusion detections systems that monitor activity within and among amanaged network in need of monitoring. Such systems typically willprovide audit trail information that identifies the files that wereaccessed by a malicious external attack by a hacker or from unauthorizedactivity by a person operating internally. Alternatively, a data breachevent notification can be generated as a result of an audit thatidentifies activities associated with a data breach occurred at sometime in the past. In either situation, the enterprise that owns ormanages the IT infrastructure can be subject to compliance-relatedactivities as set out in applicable laws, regulations, policies, rules,or contractual obligations if the managed data files associated with thedata breach event in fact comprise protected information.

Of course, there is no requirement to undertake compliance-relatedactivities unless there is protected information present in the manageddata associated with the data breach event. Thus, prior to undertakingany compliance-related activities associated with a data breach event,the nature and content of any protected information present in theaccessed managed data must be determined. That is, the collection ofmanaged data must be reviewed to determine whether it comprises anyprotected information and if so what entities the protected informationcan be aligned with.

A first step to addressing a data breach event notification willestablish the scope of a data breach for the enterprise IT network. Inmany cases, data breach events are contained to a specific server, datafile type, a person(s) having access to only certain file types, etc.Compliance-related responses to data breach events should thus besubstantially limited to those areas of the enterprise IT networkimplicated in the breach event because only those portions will besubject to compliance-related activities. To this end, digital forensicsas incorporated in intrusion detection systems operational with theenterprise IT network or implemented as tools in post-breach analysisand auditing can typically identify a collection of data files that wasactually or potentially associated with the breach event. Suitabledigital forensics activities and systems suitable for use therein areknown to those of skill in the art. Once the digital forensicsactivities are conducted to identify the areas or aspects of theenterprise IT network having managed data that was actually orpotentially accessed in the data breach event, the data file collectionderived from the enterprise IT network can then be analyzed with themethodology herein to determine whether the first data file collectioncomprises protected information and, if so, the systems and processescan be configured to assist the enterprise IT manager in undertaking thenecessary compliance-related activities associated with the data breachevent. This identified data file collection comprises managed datahaving an unknown amount of protected information therein. Such datacollection is therefore of interest to examine to determine whether anyprotected information is included therein.

Broadly, the systems and methods herein are configured to facilitateautomated review of a first data file collection derived from theenterprise IT network to detect the presence or absence of protectedinformation therein. Data files automatically identified as includingprotected information will be included in a second data file collectionthat is provided for at least some human review. Any data files in thefirst data file collection that cannot be identified with a high degreeof confidence as including or not including protected informationtherein can also be incorporated into a second data file collection asset out hereinafter.

Protected information identified in the automated review can beclassified according to a type of protected information relevant to thesubject data file collection context. Data files that have beenidentified in the automated review as having protected informationtherein are provided for human review as a “second data filecollection.” The second data file collection can then be reviewed by atleast one human reviewer to confirm the presence of protectedinformation in that data file collection, so as to allow the automateddetermination of protected information in the subject data file to bevalidated by the human reviewer. The computer can also assist the humanreviewer in aligning the subject protected information with an entity towhich the information is associated. The computer can further assist thehuman reviewer in adding the validated protected information to adatabase configurable for compliance-related activities associated withthe data breach event. Any human reviewer activities can be incorporatedas training sets for use in machine learning libraries to enhance theperformance of subsequent detection, classification, entity resolution,and compliance-related activities associated with the same data breachevent notification or other data breach event notifications for the sameor different enterprise IT networks.

As used herein, a “first data file collection” is the universe of datafiles that has been identified as associated with the data breach eventfor which compliance-related activities are associated as a result ofthe data breach. A “second data file collection” is the subset of thefirst data file collection, where the subset has been at partiallyautomatically reviewed according to the methodology for detecting thepresence (or absence of) protected data therein, as such term is definedherein. The second data file collection can include data files that areidentified by the system as having protected information presenttherein, and a confidence level for such identification can beassociated therewith. The second data file collection can also includedata files reviewed by the system that may not include protectedinformation therein, but for which the system could not provide a levelof detection at the confidence level needed for the data review process.The confidence level can be selected as a value, forexample, >0.90, >0.95, or >0.99, for example. Any data files that wereidentified at the applicable confidence level as not having protectedinformation therein can remain in the first data file collection.

With respect to the protected information detection aspects of thepresent disclosure, the methodology herein can allow identification ofprotected information in the first data file collection included inmanaged data associated with a data breach event, wherein the manageddata present in the first data file collection comprises each ofstructured, unstructured, and semi-structured data.

As would be appreciated, “structured data” is data that comports with apre-defined data model and therefore can be analyzed according to rulesoperational with that model. Structured data conforms to a tabularformat with relationships between the different rows and columns. Eachfield of data will be independent and thus can be accessed separately orjointly along with data from other fields. Common examples of structureddata are Excel files or SQL databases. Each of these have structuredrows and columns that can be readily sorted.

In contrast, “unstructured data” is data that either does not have apredefined data model or is not organized in a pre-defined manner.Unstructured data has internal structure but is not structured viapre-defined data models or schema. It may be textual or non-textual, andhuman- or machine-generated. It may also be stored within anon-relational database like NoSQL. Data that is complex orheterogeneous and cannot be fit into standard fields is unstructureddata. Unstructured data can be stored in a data lake, which is a storagerepository where a large amount of raw data is stored in its nativeformat. To manage unstructured data, NoSQL databases replace relationaldatabases as they can handle data variety and large amounts of data.Examples of unstructured data include:

-   -   Image files    -   Video files    -   Audio files    -   Medical records    -   Social media content    -   Satellite imagery    -   Presentations    -   PDFs    -   Open-ended survey responses    -   Websites    -   Data from IoT devices    -   Mobile device data    -   Weather data    -   Conversation transcripts (e.g., chat logs)

“Semi-structured data” is information that is not associated with arelational database or other rigid organizational framework but thatnonetheless comprises at least some classifying characteristics that canallow analysis. As would be appreciated, the metadata or other markersassociated with semi-structured data make it possible to separatesemantic elements and create hierarchies in data and fields. Examples ofsemi-structured data include:

-   -   E-mails    -   XML and other markup languages    -   Binary executables    -   TCP/IP packets    -   Zipped files    -   Integration of data from different sources    -   Web pages

In some situations, it can be difficult to parse the content of the datafiles in the first file collection as being entirely either the“semi-structured” or “unstructured” data types. For example, the datawithin an image file is considered to be “unstructured,” but an imagefile is also typically accompanied by metadata that can provide usefulinformation in context. However, both “semi-structured” and“unstructured” data are distinguishable from “structured” data.

“Structured data” can also be included within unstructured orsemi-structured data. For example, a table that would comprisestructured data if configured as a spreadsheet data file (e.g., excel,csv) can be included in a PDF file, in an email, or the like.

To facilitate review of the first data file collection, the collectioncan be segregated, such as by copying or removal from the enterprise ITnetwork to facilitate review, as well as to reduce the possibility thatdata files infected by the data breach might propagate through theenterprise IT network. The first data file collection can thus beuploaded onto a dedicated server or device for analysis, review, andclassification of the contents thereof.

To determine whether protected information is incorporated in the firstdata file collection, each data file in the collection is analyzedautomatically by the computer to identify information or elements ofinformation that may comprise protected information therein. Variousmethodologies can be used individually and collectively to identifyprotected information in the first data file collection comprising eachof structured, unstructured, and semi-structured data.

As would be appreciated, for data files comprising structured data,protected information comprising each of PHI, PII, and other definedterms can be readily identifiable therein because the subject protectedinformation will be identifiable by its classification in the databaseor by operation of relational databases associated therewith. That is,an automatic search for a SSN, passport number, credit card number etc.present in a structured database that are classified as such can, butwill not always, return the desired protected information result becausethe number will be included in the data in a readily searchable andretrievable form.

In other situations, the columns associated with protected informationmay not be labeled in a manner that is expected from structured data.For example, an organization or a data entry person may use a customizedor ‘bespoke” label for data that is otherwise included in a structureddata file. Such information may then be difficult to automaticallyidentify the entries in the column, even while a human reviewer might bereadily able to identify the subject data entries as being a SSN,address etc. The methodology herein can allow automatic detection ofprotected information included in a structured data file type that isnot categorized or identified in a standard, or expected, manner.

Yet further, the disclosed methodology allows analysis and detection ofprotected information in a structured data file type on a cell by celllevel, that is, on each cell independently. This is different from priorart methodologies that analyze data included in a structured data fileby considering an entire row as a single “cell” and it causes problems.For example, using these techniques, a phone number entered as7031230998 next to a cell that has a DOB as 0903, would be automaticallyidentified using prior art methodologies as 70312309980903, which wouldnot be recognized as either of the protected data types of “phonenumber” and “DOB.” In another example of prior art methodologies, thecombination of two data elements identified in a data file may becombined to form a false positive (e.g., detected as a PII element whenthe content of the combined data elements is not actually a PIIelement). In this regard, a data file can include a column for PIN 321and a column for Account number 3231298. Neither of these, within thecontext of the data file, are PII elements. But when combined using theprior art processing methods, the automatic detection could falselypredict that the subject information PII element (i.e., 3213231298)could be incorrectly identified as a SSN when in reality, it is theoutput of poor automatic identification. The present methodology canthus enhance the accuracy of such automatic identification.

PII, PHI, and other protected information that is relevant in contextwill often be present in both semi-structured and unstructured datafiles. For example, an email-a semi-structured data file—may alsoinclude the person's SSN, passport number, and credit card information,but such data will likely be present therein in a format or manner fromwhich the identity of the SSN will not be readily apparent in anautomated search if the search is not also configured with thoserelevant aspects of the SSN incorporated in the search tools. Similarly,a PDF—an unstructured data file in its printed/exported form—may includea person's SSN, passport number, and credit card information, but thedata may not be readily identifiable therefrom in an automated searcheven if the PDF has been converted to a printed/exported document.

To identify the presence of protected information in the first data filecollection, automated analysis is conducted using one or more techniquesthat are configurable to identify protected information in structuredand semi-structured files. Because a defined universe of informationtypes/content/subject matters can comprise a finite—and thusdefinable—number of protected information categories or classes that arerelevant in the context of a data breach event involving an enterpriseIT network, the inventors herein have determined that it is possible toconfigure the automated search engines to identify information thataligns with the classes or categories of protected information ofinterest. Rather than the search of the managed data being untethered toan end result, the search schema used herein for identifying protectedinformation can be configured for the identification of information thatis both likely to be present therein and that is likely to be relevantto compliance-related activities resulting from the data breach event.

To this end, the system can be configured to identify protectedinformation that is associated with a plurality of defined categoriesthat is relevant to the content of the data files affected by a databreach event can be generated. In this regard, schema for identifyingeach of a pertinent protected information type can be generated, wheresuch schema is suitable for use in identifying the protected informationof interest in managed data files comprising each of each of structured,unstructured, and semi-structured files data types.

A further insight of the inventors herein is that many types ofprotected information present in specific and consistent formats in andamong data files, especially within a single organization. Moreover,even among different organizations, professional conventions oftendictate that similar formats as used to input data. In other words, eventhough the data files might appear to be difficult to review due totheir nature as unstructured or semi-structured data types, there arealso likely to be similarities in the protected information of interestin these files that can be leveraged to facilitate the automated reviewthereof. Moreover, specifically in relation to PII, information that islikely to comprise PII will often be consistently associated with otherinformation, such as a name, address, DOB etc. Thus, automated methodssuch as machine learning, natural language processing (“NLP”), patternidentification and matching, convolutional neural networks, etc. canhave utility in the automatic detection of protected information that ispresent in a first data file collection. By automatically identifyingdata files as actually or potentially including protected information,human review of the data files associated with a data breach event canbe streamlined and human review order can be prioritized.

It has also been recognized that the presence or absence of certaintypes of other information can tend to indicate information in thesubject data file is or is likely not to comprise protected informationin context. In other words, whether information in an individual fileitself comprises protected information depends on the nature and purposeof the individual data file, and that such nature and purpose can beevaluated using automated techniques, such as NLP, pattern matching,file comparison, machine learning, convolutional neural networks, andthe like. More specifically, the application of techniques such asinformation extraction, coreference resolution, part of speech tagging,etc. can enhance the ability to not only automatically identify theinformation within context for each data file being automaticallyidentified, but also to automatically identify when specific groupingsof distributed information in a single data file are related to the sameentity. In this regard, it has been found that specific and consistentformats and patterns or the absence thereof can be leveraged to identifythe presence of protected information in the first data filecollections, as well as to provide information associated with the typeof protected information present in the collection and to provideinformation about the number of each categories.

In a non-exclusive list, search schema useful for the identification ofPII (or more broadly “personal information”) in managed data files canbe applied or developed as necessary for the following informationforms:

-   -   A person's name    -   Date of birth    -   Home Address    -   Home Phone Number    -   Personal Email Address    -   Identifiable email addresses associated with PII    -   Social Security Number or federal Individual Taxpayer        Identification Number (ITIN    -   Vehicle identifiers and serial numbers, including license plate        numbers    -   Government identification (e.g., driver's license, state ID        card, Passport number, military ID, Known Traveler Number, etc.)    -   Username and password for any online account    -   Personal phone or fax numbers    -   Biometric information (fingerprints, retina scans, facial        recognition)    -   Map and trip information (GPS tracking information)    -   Internet Protocol (IP) addresses    -   MAC addresses

For protected information that is PHI, the system can be configured toidentify protected information that is associated with healthinformation for an individual. In a non-exclusive list, rules for theidentification of PHI in managed data files can be applied or developedas necessary for the following:

-   -   Information that relates to (i) the physical or mental health or        condition of the individual; (ii) the provision of health care        to the individual; or (iii) payment for the provision of health        care to the individual.    -   Date of death (full date of death)    -   Dates of treatment (includes admission and discharge dates)    -   Medical record numbers    -   Health plan beneficiary number    -   Full-face photographs and any comparable images    -   Health Insurance Account Information    -   Payments—Payment for provision of health care for an individual.        This may include copay, premiums, deductibles, etc.    -   Treatment Information (e.g., diagnoses, treatment information,        medical test results, and prescription information)    -   Uniform Device Identifier (“UDI”): a coded number registered        with standards organizations, and would incorporate a variety of        information, including (but not limited to) the manufacturer of        the device, expiry dates, the make and model of the device, and        any special attributes that the device may possess.

For protected information that is financial information, the system canbe configured to identify protected information that is associated withfinances, financial institutions, tax records, etc. In a non-exclusivelist, rules for the identification of financial data in managed datafiles can be applied or developed as necessary for the following:

-   -   Financial account information (account number or routing number        (e.g., bank information, security codes or questions)    -   Payment card information (e.g., credit/debit card numbers, PIN,        expiration, security code, security questions, etc.)    -   Internal Revenue Service (“IRS”) PIN

As indicated, search schema can be applied from existing methods ordeveloped as needed to identify the relevant protected information fromthe first data file collection. As an example, a PIN number can beidentified in the first data file collection using an implementationthat is configured to identify a PIN in a managed data file as protectedinformation, and to further identify that PIN as likely being associatedwith a financial or tax record, as opposed to a PIN for a conferencecalling account.

In an implementation, to be considered protected information in thecontext of compliance-related activities associated with a data breachevent, the PIN must be determined to be associated with a financial orother online account and provide a way for the account to be accessed. Asearch strategy configured as [/d]{4,8} would be enough to find a 4 to8-digit pin, but this strategy would not be sufficient to determine thatthe subject PIN is related to accessing an online account as opposed tobeing a PIN for a conference call bridge or used in other purposes. Tomore accurately identify whether the a 4-8 digit number present in adata file in the first data file collection is likely to comprise a PINassociated with a financial institution or credit/debit card, the systemis configured with pattern matching capabilities that evaluate thecontext of the 4-8 digit number as it appears in the subject data file.To accomplish this, the system can be configured to detect the wordsadjacent to the PIN to establish whether the PIN is likely to beassociated with a conference call system or whether it is more likely tobe associated with a financial institution. If the former, the PIN canbe ruled out, or at least relegated to a lower priority for review,because the data file including the number is not likely to include orto be associated with protected information relevant tocompliance-related activities. If the latter, the 4-8 digit number willbe identified as being a PIN that might be accompanied by or beassociated with protected information relevant to compliance-relatedactivities. The data file can be classified by the system as includingprotected information having the category of “PIN,” where theidentification can be queued up for human review as part of the seconddata file collection.

Yet further, the methodology can analyze the data file to identify theoverall subject/context therein and to provide information associatedtherewith. For example, the system can be configured to determine thetype of data file, such as whether the data file is likely to be anemail, a meeting invitation, a medical-related document, etc. Suchidentification can facilitate the prioritization of any human review ofsuch data files, for example. Moreover, the generated information can beused to further enrich the automated analysis system for subsequent datafile review.

The system can be further configured to determine the type of PINnumber. For example, an IRS PIN is considered to comprise PII on its ownterms in some state privacy laws, whereas a PIN for a financialinstitution would not be unless accompanied by other identifyinginformation that allows an individual identity to be resolved therefrom.In this regard, natural language processes could be helpful to analyzethe text in the data file to determine whether the document sender isthe IRS. Yet further, IRS documents commonly sent to taxpayers can beincluded in feature sets used in machine learning processes and the datafile compared to such IRS letters. Other methods of deriving context foran identified PIN of interest can be utilized. Moreover, validation ofthe automatic identification by the human reviewer can add to theaccuracy of such context-based identifications.

Another example of automated analysis of the data files in the firstdata file collection is to determine whether a SSN is present therein.Prior art methods of identifying SSNs use a regular expression thatcomports with the recognized SSN format such as [/d]{3}-[d]{2}-[/d]{4}.The inventors herein have determined that this regular expressionpattern does not take into consideration spaces left between the numbersor a digit-only representation of a social security number, as mightoccur in an email, text, or transcribed audio file where a person maynot be conforming to the standard method of representing the SSN. Toaddress non-standard representations of SSN that may occur inunstructured or semi-structured files, the system is configurable to usea pattern to check for any 9-digit combination grouped in a 3/2/4fashion (including spaces or dashes between). If the system identifiesthis combination with dashes or spaces, the identified 9-digit number isvalidated as likely being an actual SSN by using the US Social SecurityAdministration rule for issuance of SSNs. The context of the text or anyother numbers used around the appearance of the SSN and in the data filein which this 9 digit number appears can also be examined via NLP,machine learning, etc. to generate a confidence level of whether a 9digit number appearing in the data file in fact is likely to comprise aSSN. For example, the results of data file evaluations where SSNs wereconfirmed to be present in a data file can be compared to a current datafile evaluation. In this regard, data files in which SSN appear areoften similar within organizations, at least because a department orindividual employees are likely to employ fairly consistentmethodologies when capturing relevant identifying information, such asSSNs. The likelihood that a number comprises a SSN or any other suchidentifying information can be associated with a confidence level, ifappropriate for a use case.

In a further implementation, if the system identifies protectedinformation at a low confidence, that information can be compared withother information in the first collection of data files for otheroccurrences of all or part of that identified information. For example,if a low-confidence SSN is automatically detected in the firstcollection of data files, that identified number can be checked againstknown/validated/high confidence instances of that number in the firstcollection of data files to determine if that sequence of digits hasbeen detected as an SSN in other data files. If it has, optionally witha context-based data file comparison, the SSN candidate previouslyreturned as a low confidence identification, the previous confidencelevel can be modified upward. As would be appreciated, such enhancementof confidence level can be incorporated in machine learning processes toenrich subsequent automated data file analysis. This approach can beused with not only SSN but other unique identifying information such ascredit card, MRN, account numbers, phone numbers, etc.

In addition to detection of protected information in a data file, thesystem can also be configured to allow validation of the presence ofsuch protected information therein by comparing the identified protectedinformation with a rule associated with that category or type ofprotected information. For example, an SSN may be detected because a 9digit number is identified in a file. The system can conduct a furtheranalysis to confirm that such number is actually a SSN, such as bycomparing the number to the rules associated with the issuance of SSNs.A credit card number or routing number may be detected due to itspattern or use within a sentence but then discarded if the validationmethod (e.g., the Luhn algorithm) does not calculate properly or if thecredit card number doesn't fall into the proper range for card issuers.Such validation can enhance the automated detection of protection byimproving the accuracy of protected information identification.

As indicated with regard to the discussion of PINs and SSNs, textsurrounding the identified information type and in the subject data filein which the identified number is present can be evaluated for contextto enhance the confidence that an identified information type iscorrectly identified and therefore categorized.

Business sensitive information can be identified by generating searchschema that is relevant in context. For example, if a breach event isidentified as occurring in a part of an enterprise IT network whereconfidential business plans are maintained, a search can be generated toidentify financial projections, business plans, or R&D information.

In a significant implementation of the present disclosure, the systemsand methods can greatly enhance the identification of protectedinformation in image data that is present in the managed data. As wouldbe appreciated, images comprise, at best, only semi-structured data forautomated processing (e.g. metadata) or, at worst, only unstructureddata. Because personally identifiable information often is included inbusiness records in the form of driver's licenses, insurance cards,passports, etc., image data must be accurately reviewed incompliance-related activities associated with a data breach event.

In some aspects, the automated review of the first data file collectionincludes an image analysis engine configured to identify image data thatlikely includes protected information, as well whether the image data islikely to not comprise protected information (e.g., logos, icons, etc.).In this regard, certain types of images likely to appear in businessrecords will include protected information. In a non-exclusive listing,image types that may be present in the managed data that includeprotected information can include: driver's licenses, passports,government or employer-issued ID cards, Social Security cards, insurancecards, or the like. The formats of these standardized data files, insome implementations, can be automatically identified and, since theyare known to incorporate protected information therein, the automatedsystem can identify these image files positively. Image data files thatcannot be automatically identified as including protected informationcan be included in the second data file collection as unclassified imagedata.

Once each of the data files in the first data file collection areautomatically reviewed for the presence (or absence) of protectedinformation, those data files identified as including protectedinformation are provided as a second data file collection.

The second data file collection is then ready for further review tovalidate the presence of protected information in each of the datafiles, as well as to assign an entity to each of the protectedinformation identified therein and to incorporate the protectedinformation into a database. Any data files in the first data filecollection that cannot be identified with confidence as including or notincluding protected information, such data files can be incorporatedinto the second data file collection for human review. In someimplementations, some image files will be included in the second datafile collection for human review thereof. Those data files in the firstdata file collection that are identified as not including protectedinformation can be retained for further review using informationobtained from actions of the human reviewer on the data files in thesecond data file collection.

When the data files in the second data file collection are categorized,the system, manager, or human reviewer can filter and prioritize reviewto focus on those categories of data files that are more likely toinclude protected information. Such prioritization can facilitate thespeed and accuracy of the overall review process by developing morerobust indexing information early in the process. Such robustinformation can, in turn, be incorporated into the processes on anongoing basis to allow pro-active processing of the data files that havenot yet been reviewed by a human and/or to allow reprocessing ofpreviously processed data files.

In this regard, the actions of the human reviewer to validate theautomatic identifications and to conduct manual data entry whereautomatic review is not yet possible will create further improvements ina data breach file collection currently under review. The human revieweraction with regard to data files in the second file collection that havebeen reviewed can be incorporated into the systems and processes toimprove subsequent review activities while the second file collectionreview is still under way. For example, if the automated identificationis determined by a human reviewer to be correct (e.g., the humanreviewer accepts this identification and categorization of protectedinformation made by the automated system), the confidence level forsubsequent identifications having the same characteristics can beenhanced. In some implementations, subsequent automated review of datafiles having the same characteristics as previously validated by thehuman reviewer can be generated with high confidence because the humanreviewer has already identified the automated review of such data filesas having a high confidence of accuracy. On the other hand, if the humanreviewer rejects the identification provided by the automated review,the system can be configured to not make the rejected identification infuture automated reviews and, optionally, to correct any data files inthe second data file collection that have not yet been reviewed. Thequality of the training sets already incorporated in the machinelearning models can thus be improved, and new training sets can begenerated.

The system or a user can generate categories of data file types in whichthe data files identified from first data file collection as havingprotected information can be classified in the automated review process.In an implementation, the categories can be generated as data elementsor information types that are likely to be included in the managed dataoverall, as well as being identified as “protected information” thereinthat is of interest for review. For example, there will likely always becategories of protected information that will be pertinent to a databreach event at least because some laws, rules, regulations, policies,or contractual obligations will be applicable to most, if not all, databreach events. This is the case for data elements that individually orcollectively are likely to comprise PII. Other managed data may beunlikely to include PHI or protected financial data; for example, ane-commerce website would generally not hold PHI for its customers. Thesystem can be configured with functionality to identify each informationtype that can be relevant to a plurality of compliance-relatedactivities relevant to the business of the enterprise that isresponsible for protecting the data of its customers, clients, patients,members, etc. The manager of the data file analysis process associatedwith the data breach event can select each relevant search functionalityas appropriate for the managed data and any protected informationtherein. Still further, the system is configurable to allow a data fileanalysis manager to develop search schema or to implement existingsearch schema to address a business case relevant to the subject matterof the managed data and any compliance-related activities relatedthereto.

While all of the data files in the second data file collection that theautomated analysis system identified as including protected informationmay not, in fact, contain protected information, the automaticidentification of such data files as potentially including suchinformation can facilitate prioritization of data files for human reviewthereof. In conducting the review of the data files in the second datafile collection, the computer, a manager of the data breach reviewprocess, or a human reviewer, can select a category of information (akadata element types) and the data files therein can be reviewed. In animplementation, for automatic selection of the data files for review,the computer can provide a suggestion to a human reviewer based upon aderived confidence level associated with the automated identificationstep. When categorized into data file types, the system, manager, orhuman reviewer can prioritize review to focus on those categories ofdata files that are more likely to include protected information. Suchprioritization can facilitate the speed and accuracy of the overallreview process by developing more robust indexing information early inthe process. Such robust information can, in turn, be incorporated intothe processes on an ongoing basis to pro-actively process the data filesthat have not yet been reviewed by a human.

In an implementation, the output of the automated review of the firstdata file collection can be filtered to identify data files that includea larger number of elements on a per data file basis. It can be expectedthat data files that are identified as including a larger number ofprotected information elements would allow more information to beextracted from a single human's review thereof. Because any extractedinformation has value in informing the ongoing data file collectionreview process, it can be beneficial for the system, a manager, or ahuman reviewer to prioritize data files having a plurality of dataelements identified in the automated process. Thus, in some aspects,review of the second data file collection can be accelerated becausesuch data files can allow a greater amount of relevant data and reviewerinformation to be developed earlier in a human review process, wheresuch relevant data and reviewer information can be incorporated intosubsequent data file review activities related to the subject databreach event.

For large second data file collections and/or short review times, aplurality of human reviewers can be employed, and the second data filecollection can be separated into batches or subsets of the whole secondcollection. The files can be checked out by each reviewer to allow eachto work on their own devices, or the reviewers can each be logged intoand conduct their own review simultaneously on a shared server. If thereviewers work on their own devices, the devices can be incommunications engagement with the other devices so that updates to thesystems from ongoing data file review can be transmitted to eachreviewer.

The computer can select a plurality of data files for human review basedupon a determined probability that the plurality of data files is likelyto be correctly identified as having protected information therein. Ifthe computer determines that the selected plurality of data files has alow probability of the automated review being accurate, such data filescan be prioritized as needing more scrutiny by human reviewers. Theactions of a human reviewer with respect to the selected plurality ofdata files can be incorporated into the systems and processes to correctany inaccurate identifications conducted, thus reducing the amount ofhuman review necessary in the entire dataset.

Still further, the data files in the second data file collection can bepresented in categories for human review thereof in any meaningfularrangement for selection and review thereof. For example, the datafiles can be categorized as only a specific type of information (e.g.,SSN, credit card numbers, medical information, etc.). Categories canalso be arranged to provide for review of groups of categories of datafiles that are identified as being likely to either comprise or to beassociated with protected information of interest in the data breachreview and compliance-related activities associated therewith. Forexample, data file types associated with “identification” or“demographic” information can be filtered for review, as those can beexpected to likely comprise PII or the like. More generalized review ofcategories such as “data files that comprise contact information” canalso be generated. Notably, the systems and methods herein can beconfigured to address the specific context of compliance-relatedactivities associated with the data breach events.

The categories can also be arranged as identified data file types forselection and review thereof, where the types are known or expected tocomprise protected information. Automated analysis of the data files canbe used to identify the type of data file. For example, machinelearning, NLP, etc. can be used to identify the nature of the data fileand to generate categories thereof. As non-limiting examples, the datafiles in the second data file collection can be identified as andcategorized as:

-   -   Invoices    -   Tax Forms    -   Mortgage Documents    -   Loan Applications    -   Bank Statements    -   Credit Card Authorizations    -   Brochures/Marketing Materials    -   Manuals    -   Medical Forms    -   Insurance Documents    -   Resumes/CV's    -   Court Documents    -   Jail Records    -   Vital Records (Birth/Death/Marriage Certificates)    -   School Related Forms    -   Company documentation marked “confidential”    -   Documentation of other companies marked “confidential”

In a further implementation, the automated review results can bepresented in a high-level arrangement that classifies the nature andtype of protected information identified in the automated analysis. Inthe context of PII, the system can identify how many data filesindividually comprise data elements that are commonly associated withPII either on their own terms or in combination with other dataelements, how many data files include only contact information, how manydata files include both a name and a PII data element, and how many datafiles contain only PII data element with information that is notassociated with contact information. As would be appreciated, the sum ofthe generated amounts of identified protected information data elementsplaced into the various categories may be larger than the number ofactual data files that require human review because a single data filemay comprise more than one type of protected information therein. Inthis regard, it can be useful to provide information to users of thetotal number of unique data file types having protected informationtherein so that the human reviewer can understand the scope of herreview and, if appropriate, the human review can be split amongst aplurality of reviewers.

As can be observed, the categorization of the preliminary data filereviews can be arranged in any way that is useful to the organization,manager, or human reviewer in context. Knowledge about the number, type,and content of data files that might comprise protected information canallow better planning and staffing of the review, which can allow theoften-onerous compliance-related deadlines to be better managed.

Data files in the second data file collection can be reviewed by atleast one human reviewer to validate the actual presence (or absence) ofprotected information therein. Data files that the automated reviewprocess identified with a high degree of confidence as not includingprotected information therein can be removed from the human reviewqueue. However, for quality control purposes, it can be beneficial toconfirm the accuracy of automated review of at least some of this groupof data files in an optional recheck step. Such a check can be by ahuman reviewer who reviews at least some of the data files identified inthe automated identification process as not having protected informationtherein as a check on the accuracy of the automated process. Such filescan be automatically selected for recheck by the computer, such on thebasis of a confidence level that the automated protected informationidentification was correct. Any user actions related to the data filere-check can be incorporated in machine learning processes to enhancesubsequent first data file collection automated review processes.Alternatively, or in conjunction with at least some human review, thedata files identified by the automated review process as not comprisingprotected information can be re-evaluated once the review of the seconddata file collection has progressed. Such later automated review canincorporate training information obtained during the human reviewprocess where previous decisions made by the automated system can bevalidated or corrected. For example, if a human reviewer consistentlyre-categorizes a specific file type in the second data file collectionfrom a first category to a second category, or from a relevant protectedinformation category to an irrelevant information category/type, suchhuman reviewer information can be used to reprocess the data files inthe present project as well as in subsequent automated first data filecollection reviews.

An improvement of disclosure herein is the inclusion of an image reviewand classification step, wherein at least some of the image data thatcould not be automatically identified in the first data file collectionanalysis step as having protected information therein can be reviewed bya human who can identify the type of image associated with each imagedata file and to allow such identification information to beautomatically applied to image data that has not yet been reviewed. Themethodology also allows image data that has previously been identifiedby the automated process as having protected information therein to bevalidated by the human reviewer.

To facilitate image data review by the human reviewer, the methodologyherein incorporates the automatic collection of a plurality of the imagedata for presentation as a grid view to allow the human reviewer toquickly select or deselect images as including or not includingprotected information therein. If one or more images in the plurality ofimages presented to the human reviewer comprises protected information,the reviewer can quickly select such images for further review so as toallow the protected information present therein to be identified. Otherimages can be marked as not including protected information. Actionsassociated with the human reviewer's selection of the presented imagesas including protected information or not having protected informationtherein can be incorporated into the processes for use in the processingother image data in either or both of the first or second data filecollections as training sets for analysis of other image data files. Thedata files can be native image files (e.g., jpeg, png, etc.) or theimages can be embedded in another file type (e.g., an image in an emailor a PDF file).

For example, the human reviewer can be provided with a batch or subsetof data files derived from the second data file collection for review.This batch will comprise data files that have been automaticallyidentified as including protected information, or as having data thereinthat the automated processes could not identify as comprising or notcomprising protected information at a high confidence level. This batchof data files from the second data file collection may include someimage data. Some of these image data files may have been automaticallyidentified as including protected information (e.g., the image fileswere identified as being drivers' licenses) and some of these image datafiles were identified as not having protected information automaticallyidentifiable therefrom. Each of the image data files can be displayed asa group of images on the human reviewer's device display. She can selecteach image file that is shown on her display that includes protecteddata. She can also select all image data files that do not includeprotected information. Upon selection of the images on her display, anew collection of images from additional image data files can bedisplayed to her for selection.

Any selections made by the human reviewer can be incorporated astraining sets for use in analysis of image data files where theautomated analysis was not able to identify the presence (or absence) ofprotected information therein. In an implementation, the first data filecollection can comprise a form of photo identification that is used inthe normal course of business for the enterprise, but which has notpreviously been identified by the system. Although such image data maybe ubiquitous in the first data file collection, the system will not beable to identify this image data if it is sui generis. However, oncethis image data has been reviewed by a human reviewer, informationassociated therewith can now be included in the training sets to allowimage data having the same form to be automatically identified as havingprotected information therein. Any manual indexing conducted to identifythe content of protected information and entity identification in thereviewed image files can also be included in training sets for use inthe current data breach review project. While there may be more humanreview of image data files and manual protected information extractionand entity identification early in the review process, as the projectmoves forward, the system will be trained to allow greater automation ofthe image review process.

The system can be trained to identify images that will not compriseprotected information, such that such images will not need to bepresented to the reviewer even in the grid format. Photos or memes thatmay have been shared by employees can also be detected and removed fromthe human review process.

Yet further, the system can display images to the reviewer withinformation how other reviewers, including the automated review process,has previously tagged or assessed a subject image or group of images, byeither or both of image content/subject matter (e.g., the presence orabsence of protected information therein) or the type of image (e.g.,identification card, driver license, Social Security card, passport,meme, selfie, etc.). When a high confidence in a previous human and/orautomated image review process is generated by a confirmation by asubsequent human reviewer, the accuracy of the systems and methodsherein can be enhanced, especially in regard to the ability to performthe review of all or part of the managed data automatically or at leastwith a lighter amount of human supervision over time as the machinelearning systems become more deeply trained.

In further implementations, an analog to the image identificationprocess can be used with other data file types. For example, a pluralityof emails, word-processing documents (e.g., Word, Google Docs, etc.),spreadsheet files, etc. can be collected for presentation of a pluralityof each data file type as a collection or a mix of data file types onthe user's display. The user can select or deselect each of theindividual data files in each collection as comprises at least someprotected information elements. This can enhance the review of datafiles as either having/confirming protected information elements thereinfor generation of the second data file collection and/or for the reviewof such data files in the second data file collection. The informationgenerated therefrom can be incorporated into data file review processesfor the present data file collections and used elsewhere.

In a further aspect of the methodology, a batch of data files that havebeen identified as potentially including protected information are each,independently, queued up to one or more human reviewers foridentification of the protected information therein and to generateentity identifications as required for compliance-related activities.

To this end, a human reviewer, or more typically, a group of humanreviewers, will be provided with a collection of data files thatpotentially comprises protected information and that therefore will beassociated with compliance-related activities associated therewith.Depending on the applicable laws, rules, regulations, policies, orcontractual obligations, the type of protected information in the datafile, and the person or organization affected by the data breach event,there may be a variety of requirements for notification, remediation,and liability associated with the subject data breach event. In order tocomply with such requirements, the protected information present in thedata files must be aligned with or linked with an entity that isidentifiable from a data file or a collection of data files and theprotected information therein must be identified. That is, in order tocomply with applicable laws, rules, regulations, policies, orcontractual obligations, the process must allow determination of whatentity was damaged or potentially damaged by the breach by connectingthat entity with any and all protected information that was involved inthe data breach.

As should now be apparent, the “who” and “what” are not trivialdeterminations in data breach events involving large numbers of datafiles of different types that involve many entities that may havedifferent forms and content of entity identifications included in themanaged data set. For example, a person's insurance card typically doesnot include information that is personally identifiable for that personother than the insured's name and proprietary insurance planidentifiers. (However, an insurance card will comprise “personal data”as defined by the GDPR). Thus, an insurance card by itself may notcomprise “PII” as defined in one or more applicable laws, regulations,rules, and policies. However, a managed set associated with a databreach event may contain medical records where a patient's name isblanked out for privacy reasons, with the information for billingpurposes included as insurance plan information. Thus, the combinationof the insurance card and the medical record together would constituteboth PII and PHI for that person. Using prior art review methods,information extracted from the various data files by a human reviewerwill be incorporated in different spreadsheet columns maintained in asingle spreadsheet by that reviewer. In the example, the column for“name” would be filled out for the insurance card, but for the medicalrecord, there would be no “name” column populated. However, for each ofthe individual files, the column with “insurance plan information” willbe completed. Thus, compliance-related activities associated with themedical record will require the step of cross-matching the variouscolumns generated from human review. As would be appreciated, this canbe a highly time intensive process, especially when a large protectedinformation data breach event occurs.

These human reviewer-generated spreadsheets are also typically preparedand maintained by a plurality of individual reviewers during preparationthereof, each of whom will be responsible for a batch of files in thesecond data file collection. Each reviewer will then manually enter theinformation for their own batch or subsets of data files, which theywill check out of the master collection. Practically speaking, thesespreadsheets cannot be cross-referenced until the entire human reviewprocess is completed, which could effectively prevent completion ofcompliance-related activities in the required time period, even when thehuman review may have been substantially completed by the deadline. Thatis, sin full and complete knowledge of the content and amount ofprotected information associated with a data breach amount cannot begenerated in prior art methods until after the end of each individualreviewer's efforts are merged, cleaned, and validated by a qualitycontrol individual(s).

Moreover, for enterprise IT networks that contain a large amount ofpersonal information maintained in each of structured, unstructured, andsemi-structured forms as appropriate in the context of disparatedepartments or functions, the same protected information may bemaintained in a number of ways for a single entity. For example, apatient's client intake record could include a scan of her insurancecard and a hand-completed medical history. This insurance card andmedical history will typically be incorporated into a structured dataentry form by an administrative clerk for use in generating a medicalrecord for that patient. When the medical team examines the patient, themedical record may be generated as a combination of unstructured data(e.g., doctor's observations by text entry) and structured data entry(e.g., medical coding). The patient may communicate on her patientportal in email or chat form to her medical staff. Employees of themedical provider office or system may communicate about the patient viaemail; for example, a doctor might email a nurse directing her toperform some medical task for “the patient in Room 123,” without usingthe patient's name. However, other information can allow the identity ofthe patient in Room 123 to be determined, thus the email would beassociated with both PII and PHI for that patient. In order to identifythe “patient in Room 123,” it is likely that a plurality of data fileswould need to be reviewed and indexed to allow the identity of thatpatient to be obtained, thus making compliance-related activitiesassociated with the “patient in room 123” onerous and time consuming. Ofcourse, a data breach event will generally not involve only a singleentity, meaning that similar deductive reasoning will have to beconducted for each affected patient.

The present disclosure automates at least some of the deductivereasoning needed to identify entities having data that may have beenaffected by a data breach, even when the name of the entity may not beuniformly provided on each of the data files, and the overall scope andcontent of the protected information in a collection of data files foreach entity may not be determinable from a granular review of each datafile.

The present disclosure incorporates a process to assist the humanreviewer in aligning a plurality of data files comprising protectedinformation with a single entity even when the entity may be identifiedusing different entity identifications in at least some of the datafiles. For example, some data files may use a person's first name andlast name, or just a first initial or last name. Other data files mayuse only a code for the person, and another data file will match listboth the code and the person's name, although the name as presented inthis data file may be presented as last name first, with first andmiddle initials. In order to properly associate the correct entity—thatis, a person—with this collection of data files, the methodology hereinperforms an entity resolution process, As would be understood, “entityresolution” pertains to the identification and linking of differentmentions of the same entity in a single data source or across multipledata sources. By way of further explanation, “entity resolution” is themerging of information in a data file with an entity when suchinformation is determined to be associated with an entity of interest.In short, entity resolution aligns specific information in a data filewith an entity. In the present disclosure, the entity to be resolvedaccording to the processes herein are each of the persons, group ofpersons, organizations, or companies that are associated with each datafile in the second data file such that one or more data files eachcomprising protected information are correctly linked to a single entityassociated with the protected information.

Various methods of entity resolution can be implemented in thedisclosure herein, such as that in U.S. Pat. Nos. 10,223,429 and10,387,780, the disclosures of which are incorporated herein in theirentirety.

Various entity identifiers found in a data file can be used to align orlink one or more protected information data elements in that data fileto a single entity. A single data file can include more than oneprotected information data element and/or can be associated with morethan one entity identification. In a non-limiting list, these caninclude: full name, first name only, first initial and last name, lastname only, address, IP address, email address, MAC address, date ofbirth, full social security number, last four digits of social securitynumber, driver's license information without state of issue, driver'slicense information with state of issue, passport information, tax idnumber, health insurance identifiers, PIN, phone number, websitepasswords, bank account information, zip code, credit card number,security password (e.g., mother's maiden name, first pet, etc.), UDI,and any others that are relevant in context.

Some entity identifiers may not be unique to a single person or entity,but when combined with other identifiers, the entity can be known withcertainty. In other words, a plurality of personal data elementsassociated with an identified entity can collectively comprise “PII,”“personal information,” etc. For example, names and dates of birth maybe shared by more than one person. The disclosure recognizes that whenresolving an entity—that is, when a name/identity is being determinedfrom a plurality of data files—the universe of information that would berelevant thereto can be framed according to values that can be expectedto be present in the data files. Such an approach can be used across toidentify entities from data files associated with the enterprise that isthe subject of the data breach event.

In some implementations, expected entity values can be associated withattributes such as:

-   -   Frequency—does one, few, many, or very many entities generally        share the same value, e.g., an SSN is commonly used by one        entity, an address is shared by a few, and a DOB is shared by        many?    -   Exclusivity—does an entity typically have just one such value,        e.g., an entity should have only one SSN or DOB, or is the value        non-exclusive, e.g., an entity can have more than one credit        card number?    -   Stability—is this an exclusive value that is generally constant        over an entity's lifetime, e.g., an SSN and DOB are typically        stable over a lifetime, or does it typically change, e.g., home        address?

In a further example, if two persons named “Robert Smith” live at thesame address but each has a different DOB, three of four entityidentifiers (first name; last name; address) would be the same, but anidentifier that is stable over a lifetime is different for each of thesepersons. Thus, a conclusion would be drawn with a high confidence thatthese are two different persons, likely father and son. If one man wasidentified as “Robert Smith” in some data files and “Bob Smith” in otherdata files, but the same DOB and address was present for both names in aplurality of data files, a conclusion would be drawn that these were thesame people with a high degree of confidence, at least since “Bob” isknown to be a very common nickname for a person with the given firstname of “Robert.” To this end, it would be highly improbable that twomen with the same or common alternative of the same first name who sharethe same address would also share the same DOB. Thus, a probability canbe generated that allows an entity to be identified when a plurality ofdata files comprise matching but not necessarily identical entityidentifiers for an entity. The number of the plurality needed togenerate an acceptable probability of the collection of data filesconforming to the same entity will depend on context (e.g., type ofidentifier, commonality of identifier, etc.), and can be determined byone of ordinary skill in the art and in accordance with existing anddeveloped rules. In implementations, a confidence level can be selected,and if the probability that the plurality of data files is associatedwith a single entity is below the selected confidence level, theplurality can be presented to a human reviewer for completion of theentity resolution step. The actions of the human reviewer can beincorporated into a machine learning library for use in subsequententity resolution processes.

While at least some of the expected entity identification attributes canbe pre-assigned to the entity resolution system, the system can beconfigured to learn more entity identification attributes over time. Forexample, each enterprise will likely have various conventions associatedwith data input formats to identify customers, patients, clients, etc.that may not be expected in the abstract but that will become apparentwhen data files from that enterprise are processed according to themethodology herein, especially when such data files are reviewed by ahuman. Such conventions can be stored for use as machine learninginformation in subsequent data breach review events for the sameenterprise or for other enterprises, as appropriate.

An insight of the inventors herein is that as a data breach notificationreview progresses, the human reviewer(s) will generate knowledge abouteach of data file types, protected data contents, and entitiesassociated with the first and second data collections. The humanreviewers will become more competent with the data files to allow theirreview to be conducted more quickly. Moreover, the human reviewervalidation or correction of data files will generate both more featuresets and higher confidence levels for the automated review. This ongoinghuman reviewer action can therefore improve the speed and accuracy ofthe overall review for a single data breach event.

With each data file breach review, the automated processes can also beexpected to generate at least some domain knowledge for enterprises thatare likely to include data files of a similar type. For example, if adata breach event file data collection review is conducted for ahospital system, it can be expected that the automated processes canprovide an improved first order review of data file collections foranother hospital system. Over time, the systems will generate at leastsome domain knowledge for businesses that are associated with the sametype of data collection operations. The machine learning librariesgenerated from one or more enterprise IT network breach events cantherefore be used in a subsequent breach event data file review.

A further aspect of the methodology herein includes a functionality thatassists a human reviewer in her review activity. This functionality isoperational in the background during the human review process, andincorporates actions and insights generated from each of the humanreviewers, where such actions and insights can be incorporated into theprocesses as the review of the batches or subsets of data files arereviewed by each of the human reviewers. When a new data file in thesecond data file collection is reviewed by a human reviewer and thereviewer identifies relevant information on that data file (e.g., name,SSN, DOB, etc.), the system is configured to analyze previously reviewedand indexed data files to see if any of that same information hasalready been incorporated into the database incorporating previouslyreviewed data files where such review has been completed. If apreviously identified entity is determined to be the same as an entityassociated with the present data file review, the data file informationwill be linked with the existing entity information and associatedprotected data automatically so that all protected information known tobe associated with a previously identified entity can be groupedtogether for all of the data files in the second data file collectionhaving that same entity identification for each of the batches for eachhuman reviewer. If any protected information that is now linked to aknown entity was not previously associated with an entity, thatpreviously unaffiliated information will now be grouped automaticallywith the known entity in real time. For example, medical informationcould have been in a data file with only a number as an entityidentification. In a later reviewed data file, the number appears alongwith the person's name. The numbers in each data file can then be linkedto the person, and any protected information in the data files will nowbe associated with that individual by name. Further, if information waspreviously grouped with another entity such that there is now more thanone entity grouped with the same protected information, such informationwill be flagged for additional review.

Information associated with entity groupings and any corrections relatedthereto can be incorporated into the processes herein. In this regard,context associated with the linkage of data files to an entity (e.g.,person(s), company, organization etc.) or entity category (e.g.,customer, patient, client, etc.) can be incorporated into the processesto further improve the machine learning for this project and others,such as by enhancing the ability to extract useful information out ofunstructured and semi-structured data.

It should be appreciated that because the database is generatedthroughout the data file review process, the effort required to createan accurate compliance-related database can be greatly lessened incomparison with prior art methodologies. To assist withcompliance-related database completion, the system can be configured toallow the user interface to allow not only for data file review andexploration, but also to allow review and editing of theentities/individuals affected by the data breach event during thecompliance-related database generation in real time. In this regard, thesystem can be configured to display all identified information generatedfor each individual/entity identified from the data files as beingaffected by the data breach, including all personal information, relatedor duplicate individuals, and related data files. Such “unified view”can be generated during human review to provide a real time assessmentof the scope and content of the protected information associated with anidentified entity during the review process. It is expected that byallowing a human reviewer to observe the entity resolution process andany protected information and linking associated therewith as theprocess is ongoing can serve to reinforce the understanding of the humanreviewer of the generated compliance-related output in context. That is,rather than being conducted in a vacuum, the human reviewer can gainincreased understanding of the process in real time. This can result inthe human reviewer being able to more quickly conduct the review as shebecomes more knowledgeable about the process in context (e.g., repeatedoccurrences of a name and address for a person can be accepted morequickly, nicknames, etc.), she can also be better able to identifyanomalies in the data (e.g., a misspelling in a name or address, marriedname vs. married name, transposed SSN etc.).

Yet further, the human reviewer can be provided with a unified view ofthe entities and linked protected information at the end of the reviewprocess. As would be appreciated, at the end of the review process, aunified view of the entirety of the data files having protectedinformation for each identified entity will be appropriate foraddressing compliance-related activities for that identified entity asappropriate for that specific entity. The human reviewer, who at the endof the process should have a deep understanding of the informationdeveloped during her work, can review the compliance-related databasesection that she generated as a quality control check.

The system can further be configured with additional functionalityassociated with entity resolution. For example, the system can employdata provided by the enterprise to enhance the knowledge base includedin the system at the front end. The enterprise can provide lists ofknown persons who are likely to have been associated with protectedinformation. If a portion of an e-commerce website's stored credit carddatabase is hacked, the e-commerce business can provide a database ofknown customer information to populate the system knowledge base.Sources of data, such as HR directories or customer relationshipmanagement databases can be imported into the systems to assist inentity resolution, such as by confirming contact information. As wouldbe appreciated, having such information to seed the machine learninglibraries can improve accuracy of the automatic searching andidentification using the methodology.

Still further, the entity resolution engine can learn from humanreviewer interaction and use this information as training in machinelearning systems to identify when multiple pieces of information maybelong to the same person, even if a human reviewer has not previouslyfound this particular person's information. For example, in an emailfrom Todd to John referencing Peter, his date of birth, and his SSN, thesystem can be configured to recommend to the human reviewer that Peterhas multiple pieces of information in the data file. The technologydescribed herein can be used to automatically build out the entity list.Likewise, the system can be configured to assist a human reviewer inmapping entity and protected data to the laws, regulations, policies,procedures, and contractual obligations thereby significantly reducingthe manual entry effort.

A further significant implementation of the present disclosure is anautomated data file identification and description process that reducesthe time needed to review each of the data files in the second data filecollection, which can be highly relevant to compliance-relatedactivities that are, in many cases, subject to strict deadlines. Thisautomated process also can reduce input errors and enforce consistencyamong human reviewers at least because the format for data entry isstandardized by data file rules defining the highlighting of theidentified portions of each data file. This standardization can also beuseful to reduce the time needed to complete the compliance-relateddatabase due to the consistency forced between human reviewers thatsubstantially eliminates the ability of a reviewer to generate her own“flavor” of data entry.

Known functionality and formatting of data files can be leveraged toenhance the ability to derive information therefrom automatically or atleast with reduce the need for manual effort. For example, when a datafile is identified as being a PDF, form extraction can be used toidentify fields in the subject data file to provide information aboutthe subject matter of any text entry therein. The text in a fieldidentified to be associated with protected information can also beautomatically derived from the PDF document (e.g., fields identified asPII entries: SSN, name, DOB, etc.).

In another example, metadata associated with data files can be utilizedto provide insights into whether a data file may (or may not) be likelyto include either or both of information about an entity that may beaffected by a data breach or protected information. As an example, imagedata files generally include both content-related metadata andlocation-related metadata. One or more image metadata types can beautomatically reviewed to identify multiple occurrences of the sameimage that can be identified with high confidence as not comprisingprotected data (e.g., logos, memes, etc.). Similarly, image metadata canbe automatically reviewed to identify image data that is likely tocomprise protected data. For example, a plurality of images that havelocation data associated with the GPS coordinates of a hospital can beidentified as having a higher probability of comprising at least someprotected data. In another example, content metadata in data files canidentify an author, editor, etc. If the person or department indicatedin the content metadata can be determined to be associated with a personwho is known to commonly be associated with protected data creation(e.g., a medical provider, a lawyer, etc.) that data file can beidentified as likely comprising protected information. If a data file isidentified as having a high probability of comprising protectedinformation, the human reviewer can be provided with information relatedthereto. In some situations, it may also be possible to accuratelyidentify a data file as having protected information therein byidentification of the information therein by methods such as fieldidentification for PDF data files, optical character recognition,application of training sets where protected information has previouslybeen identified, pattern matching etc. If such protected information canbe identified from the data file automatically and the system candetermine that such identification is made with a high degree ofconfidence, the human reviewer can be provided with information in thatregard. In some situations, such as with multiple occurrences of humanreviewer confirmation of the system correctly identifying the content ofa data file type, the system can automatically generate the protectedinformation determination, which can from time to time be subject tohuman review to ensure that the automatic identification continues to becorrect.

In a first implementation of the automated data file identification anddescription process, the system is configurable to automaticallyhighlight relevant information detected in a data file, where thedetected information is associated with an entity and/or protectedinformation that is present in the subject data file. Once highlighted,the human reviewer can review the highlighted section(s) in the datafile and, if she accepts the automated identification as being correctin the context of the subject data file, as well as in the ongoingsecond data file collection review, she can select the highlightedsection(s), such as by clicking a mouse or using a touchscreeninterface. The entire highlighted section can then automatically beincorporated into a database record associated with the data file. Ifthe human reviewer does not agree with the automatically highlightedsections(s), she can reject the highlighted portions, and optionallymanually input a reason for the rejection, as well as any relevantcorrections. The actions of the human reviewer with regard to theautomated identifications can be recorded as information for use in datafile review for the same enterprise IT network, as well as to trainmachine learning processes used for other enterprise IT networks.

The sections in the data files displayed to the human reviewer can behighlighted according to a standardization by color coding for theautomated data file information type suggestions. In this regard, anidentified entity name can be highlighted as a first color, a creditcard as a second color, a SSN as a third color, etc. Once the humanreviewer becomes familiar with the color-coding framework, the reviewingprocess can become faster.

In a second implementation of the automated data file identification anddescription process, entry of information included in data files thatcomprise a large amount of similar information can be automated so thatthe human reviewer does not need to separately identify the unique datafor inclusion in the compliance-related database. When the humanreviewer is presented with a structured data file that includes aplurality of names, such as patient names, SSNs and DOB's, the system isconfigurable to automate the entry of such information into thecompliance-related database. In this regard, the human reviewer canselect each of the columns and align such information with theassociated compliance-related database columns. As would be appreciated,such an automated database population can greatly reduce the amount oftime needed to populate the compliance-related database, as well asincreasing the accuracy of data entry. Again, the actions of the humanreviewer can be recorded as information to be used in machine learningprocesses so that the next time a similar data file is identified in thesecond data file collection, the system can provide the proposed actionof auto-population of the compliance-related database as a suggestedaction to the human reviewer.

In a further example, for data files comprising tables, the informationtherein can be automatically extracted to populate thecompliance-related database. Such tabular data can be embedded in a datafile, such as an email, PDF, or the like: in other words, the system isconfigured to process structured data that is embedded in unstructureddata. The system can automatically extract the tabular data to identifythe protected data elements therein and identify and associate anyentities therewith. In contrast to prior art data file review methods,the methodology herein does not treat tabular data as informationwithout context as a “bag of words” where the tabular content isextracted, indexed, and then automatically reviewed. The methodologyherein is configured to identify tabular data in a data file, identifyone or more relationships between and among the tabular data, andassociate the tabular data with the identified relationships. The systemcan then extract the tabular data along with the identifiedrelationships. The system can be configured to identify the nature andcontent of the data and to extract any relationships therefrom. In someimplementations, the methodology can be configured to generatestructured tabular data from unstructured tabular data.

As would be appreciated, the first time the automated system encountersa data file where the unstructured tabular data is embedded in anunstructured file, the nature and contents of such file may be difficultto analyze. Thus, such a file may likely be presented to the humanreviewer. Once such a document is manually reviewed, the output of thehuman review will then be included as a feature set in machine learningsystems. Over time, automatic review of such data files can be conductedwith high confidence to further reduce the manual work needed for datafile review.

In a further implementation of the automated data file identificationand description process, once a human reviewer selects a combination ofinformation in a data file from her display, the system can beconfigured to automatically review the other, not yet reviewed, datafiles in the second data file collection to identify any appearance ofthat same combination in the not yet reviewed data files. To this end,data files generated by the same enterprise will often have a standarddata entry format that is unique to that enterprise. It can be expectedthat a second data file collection derived from a data breach event willcomprise data files from one or more areas/departments of the enterprisehaving similar data entry conventions. The generation of thecompliance-related database can be streamlined and accuracy improvedwhen such data entry conventions are identified in the second data filecollection and automatically propagated through other data files thereinhaving the same data combinations.

Yet further, a functionality of the methodology herein is the ability todetect anomalies, such as irregularities in text. An example of ananomaly of interest would be when two entities are identified as havingthe same identifying information, when such persons should not. Usingthe father and son “Robert Smith” example previously discussed, if thename “Robert Smith” living at the same address is associated with twodifferent DOBs, a potential anomaly will be presented to a humanreviewer for validation or correction. Anomaly detection functionalitymay also be relevant when two occurrences of identified protectedinformation associated with an entity are very similar, such as mightoccur with a typographical error. In this regard, when an entity hasmore than one data file from which the entity identification isgenerated, anomaly detection functionality reviews the informationassociated with the entity identification and each of the data filesthat the entity information is associated with to determine which pieceof information is likely to be more accurate. For example, if anidentified entity is associated with a SSN of 231-09-0998 that isderived from eight data files and a SSN 231-09-0999 that is derived fromone data file, anomaly detection will analyze the number of data filesassociated with each SSN to help determine which SSN most probablybelongs to the entity in question. A suggestion for the correct SSN canbe made to the human reviewer for confirmation thereof.

To ensure that all protected information was identified in the firstdata file collection, a second automatic protected information searchcan be conducted thereon later in the review process. In someimplementations, it can be beneficial to conduct such automatic reviewat the end of the review, as it can be expected that at that point theprocesses will include significantly more training sets and otherlearning that can enhance the automatic search capability to ensure thatdata files previously identified as not including protected informationin fact do not comprise protected information. This can serve as adouble check on accuracy of the compliance-related database.

Instead of generating the notification database from a collection of aplurality of individual reviewer spreadsheets or other type of databaseentries after each of the individual tasks are completed for eachreviewer, the systems and methods herein generate the mastercompliance-related database from a collection of reviewer databaseentries where each reviewer contributes thereto as thecompliance-related database is being generated. In other words, unlikewith prior art methods where each human reviewer creates an independentcompliance-related database portion from her own review activitiesfollowed by merging of each independent reviewer compliance-relateddatabase, the present methodology automatically creates a mastercompliance-related database that where each reviewer effectivelycollaborates. By such collaboration, any new database generationactivities by each of the plurality of human reviewers, as well as anyautomated activities associated therewith, can be incorporated in thecompliance-related database preparation in real time. Such real timecollaboration has the benefit of allowing at least some entityresolution activities to be conducted in real time while thecompliance-related database is being prepared, such as by reducing theneed of each individual reviewer to independently perform entityresolution activities. Further benefits to this collaboration areprovided by the ability for one or more individual reviewers to identifypotential errors in entity resolution activities to be flagged for otherreviewers in the group of reviewers so that such notification ofpotential errors can be propagated amongst all the reviewers. Suchcollaboration is akin to the “wisdom of crowds,” wherein the “crowd” isthe group of individual reviewers and the “wisdom” is the collectivegenerated knowledge of the group, to enhance the accuracy and speed ofcompliance-related database preparation so that compliance-relatedactivities can be effectively performed from such output. The processesherein can be considered to provide a methodology that allows thecompliance-related database entries to “self-correct,” in that errors oromissions in the data identifications and entries can be automaticallygenerated in the database record substantially without manualcorrections.

The process also provides a collection of database information for eachentity identified in the review process. The collection of informationavailable for each identified entity can comprise at least all protectedinformation identified for each identified entity that was associatedwith the data breach event, related or duplicate entities identified,and data files associated with each identified entity that do notcomprise protected information. A level of confidence can be presentedfor each data file associated with an identified entity and/or relatedor duplicate individuals, where the level of confidence can serve as away to identify compliance-related database information that should bemanually checked for accuracy. Any information associated with a humanreviewer's identification and operation of correction and accuracychecks of one or more compliance-related database entries can be storedin the machine learning library for subsequent use, thereby improvingthe accuracy of subsequent reviewing activities.

The generated compliance-related database can then be used incompliance-related activities associated with a data breach event. Inthis regard, the compliance-related activities can comprise one or moreof receiving a plurality of compliance-related requirements associatedwith a data breach event, determining whether one or more of theplurality of compliance requirements are relevant to one or more of theentities in the compliance-related database, and performingcompliance-related activities associated with each to the identifiedentities.

As would be appreciated, whether each of a plurality ofcompliance-related activities is relevant to an identified entity willdepend on the location/citizenship/residence of the entity, the datafiles associated with the identified entity, and the regulating bodyassociated with a laws, rules, regulations, policies, or contractualobligations, among other things. In this regard, some states will notrequire notification to either or both of each identified entity and theregulator or will otherwise impart liability for a data breach at anytime, whereas some states may require notification of a data breach toaffected entities within a short period of time. For the EU, the GDPRrequires notification within 72 hours of the breach notification to allaffected entities for any data breaches involving “personal information”as identified in the regulation. The wide variety in not onlyjurisdictions but also in the nature and scope of compliance-relatedactivities associated with a data breach notification—as well as anypenalties or liability for non-compliance thereto-thus requirescontextual assessment of the compliance-related database as toidentified entity, location/residence of the identified entity, and thecontent of each data file associated with the identified entity.

The present technology can also provide a risk assessment based on thenature and scope of a data breach as shown by a compliance-relateddatabase. These risk assessments provide specific information to anenterprise regarding the severity of the data breach relative toapplicable laws, rules, regulations, policies, or contractualobligations. The data risk assessment can provide information associatedwith the level of protected information associated with the data breach.For example, the manager of the enterprise IT network can be presentedwith a dashboard configuration that provides a comprehensive overview ofthe affected identified entities by department, customer type, customerlocation, employee, patient(s), type of customer data files associatedwith the data breach, etc. The dashboard can be color coded to indicatethe severity of the data breach in various contexts. Such informationcan be consolidated into a report form or otherwise used for “afteraction” activities associated with compliance-related activities.

In further implementations, the systems and methods herein can beconfigured to generate automatic notifications of the data breach toeach identified entity as required by each applicable laws, rules,regulations, policies, or contractual obligations. In this regard, areporting obligation associated with an identified entity is determinedfor an identified entity, where the reporting obligation is derived fromat least the applicable laws, rules, regulations, policies, orcontractual obligations, the residence, location, or citizenship of theidentified entity, and whether protected information for the identifiedentity was present in or can be derived from the data files associatedwith the identified entity. If a reporting obligation is present, thesystem is configurable to provide such automatic notification via letterusing address information derivable from the compliance-relateddatabase. If a return notification is obtained (e.g., via returnedletter, “bounced” email), such information can be used to update thecompliance-related database and other information associated with theidentified entity.

Referring now to FIGS. 1A and 1B, shown are flow charts illustratingexamples of identification and management of compliance-relatedactivities after a data breach associated with an enterprise IT network.Beginning at 102 of FIG. 1A, a (first) date file collection associatedwith a data breach event is received by at least one computer (e.g., aserver or cloud computing system). The data file collection can begenerated by analysis of the data breach event. For example, the datafile collection can be derived from a bulk data file collection storedon or associated with an enterprise IT network of interest formonitoring for an occurrence of data breach events. The first data filecollection can comprise at least some of structured, unstructured,and/or semi-structured data file types. At least some of the first datafile collection can include protected information havingcompliance-related activities associated with in.

Information associated with the protected information elements can begenerated for all or part of the data file collection by the at leastone computer at 104. The information can be associated with the presenceor absence of the protected information elements. If the generatedinformation indicates that a data file in the data file collectionincludes the protected information elements, that data file can beincorporated in a second data file collection thereby generating asecond data file collection at 106. Data files of the second data filecollection can then be analyzed by, e.g., a human reviewer to validatewhether the data file comprises one or more of the protected informationelements. For example, a subset of individual data files selected fromthe second data file collection can be analyzed to validate that eachdata file in the subset comprises at least one protected informationelement.

If it is determined at 110 that the one or more protected informationelements are not present in a data file, then that data file can beremoved from the second data file collection e.g., by the humanreviewer, and re-incorporated into the first data file collection at112. If it is determined at 110 that the one or more protectedinformation elements are present in a data file, then at least oneentity identification for an entity associated with the protectedinformation elements in that data file can be derived at 114 by eitheror both of the human reviewer or the at least one computer. The entitycan comprise an individual, a group of individuals, an organization, ora company. Based the protected information elements and associatedentities, information associated with one or more protected informationelements and the associated entity can be generated at 116. Theinformation can be generated by either or both of the human reviewer orthe at least one computer.

At 118, the information associated with the analysis of the subset ofindividual data files can be incorporated into machine learninginformation by, e.g., the at least one computer. The information can bestored in, e.g., a machine learning library at 120 and configured forsubsequent analysis of either or both of the first and second data filecollections. The information in the machine learning library can also beused for analysis of other data file collections, which can beassociated with the same data breach event or another data breach event.

For example, at least one computer can provide a machine learninglibrary at 130 in FIG. 1B. The machine learning library can be generatedusing, e.g., the method of FIG. 1A. At 132, a data file collectionassociated with a data breach event is received. The data breach eventmay be associated with the data breach event used to generate themachine learning information of the machine learning library or withanother data breach event. The data files of this data file collectioncan be analyzed at 134 for the presence or absence of protectedinformation. The analysis can be based, at least in part, upon theinformation in the machine learning library. Entity identification canthen be derived at 136. A compliance-related database can be generatedat 138 based upon the analysis. The information in thecompliance-related database can be used to generate notificationsassociated with the data breach even at 140, which can then be providedto the identified entities.

FIG. 2 shows a block diagram illustrating an example of a system 200wherein the framework for processing electronically stored information(ESI) such as managed data (e.g., structured data, unstructured data,and/or semi-structured data) and generating a user interface can beimplemented. One or more applications can be executed to implement theframework for processing ESI and generating the user interface in thesystem 200, and the various components in the system 200 (such as theclient system(s) 210, server system(s) 220, and/or external system(s)230) can perform different functions related to the deployedapplications. In one non-limiting example, the external system(s) 230may generate a user interface showing information related to theprocessed ESI so an end user may make an informed decision regarding theuse of such information.

FIG. 2 shows applications or software modules that can be executed byprocessing circuitry at the external system(s) 230, server system(s)220, and the client system(s) 210; it should be understood that theapplications or software modules shown in FIG. 2 are stored in andexecuted by hardware components (such as processors and memories) andprocessing circuitry; details regarding example hardware components thatmay be used to execute these applications or software modules areprovided below with reference to FIG. 4.

One or more client system(s) 210 can be configured to store ESI 212having managed data can comprise each of “structured data,”“unstructured data,” and “semi-structured data or other informationrelated to one or more topics. The ESI 212 can be an electronic datamessage and/or a data file formatted for processing by server system(s)220. For example, the ESI 212 can include, e.g., email messages, wordprocessor documents, spreadsheet documents, electronic presentationdocuments, images and/or portable document format (PDF) documents. Theseexamples are of course non-limiting and the technology described hereinenvisions ESI 212 taking any variety of forms.

Server system(s) 220 can be configured to communicate with clientsystem(s) 212 and external system(s) 230 (e.g., via network 215). Itshould be appreciated that the network 215 can comprise a network ofinterconnected computing devices, such as the Internet. The network 215can also comprise a local area network (LAN) or a peer-to-peerconnection between the different devices in the system. The serversystem(s) 220 can comprise one or more computers, computing devices orserver devices including, but not limited to, database servers, fileservers, web servers, application servers, a server cluster (e.g., acloud based computing environment), a standalone server, and/or anyother portable or stationary computing device having server-basedcapabilities. It should be appreciated that the server system(s) 220 canbe implemented using separately located hardware (e.g., remote hardware)or can be implemented using a same piece of hardware (e.g., within asingle housed server device).

Server system(s) 220 can receive the ESI 212 from client system(s) 210via network 215. Upon receiving ESI 212, an information extraction andanalysis application can analyze data files to generate informationrelated to protected information elements. For example, the extractionmodule 222 of server system(s) 220 can be configured to parse differentelements in the ESI 212. For example, extraction module 222 may parseword processing documents or email messages for various data and thenprovide the parsed and extracted data to analysis module 224. In onenon-limiting example, analysis module 224 can analyze the parsed andextracted data to look for certain information that may be consideredsensitive and open to being compromised. As an example, analysis module224 can analyze the data to associate different individuals or entitieswith certain personal information elements including, but not limitedto, social security numbers, personal address information, credit cardinformation, sensitive health information, and/or bank accountinformation.

Once a data file has been extracted and/or processed, the system(s) 220can store the extracted and processed data in database 228. The database228 can be or include one or more of: a relational database managementsystem (RDBMS); an object-oriented database management system (OODBMS);an object-relational database management system (ORDBMS); a not-onlystructured query language (NoSQL) data store; an object cache; adistributed file system; a data cluster (based on technology such asHadoop); and/or any other appropriate type of data storage system).

The server 220 can further include an application server 226 that can,for example, execute server-side (or “back end”) instructions forapplications that run on the server system 220. In one non-limitingexample, the application server 226 can generate data associated with auser interface that is displayable on a display connected to externalsystem(s) 230.

The external system(s) 230 can include software components forperforming processing related to applications deployed in the system. Asa nonlimiting example, the external system(s) 230 may have a clientapplication 232 comprising a rendering module 234, a networking module236 and a software module 238. Of course, these modules are anon-limiting example, and the client application 232 can compriseseveral more modules and/or different modules than those illustrated inFIG. 2. The external system(s) 230 can comprise any variety ofclient-based devices including, but not limited to, a personal computer(e.g., a desktop computer, a laptop computer), a thin client, a hybridclient, a rich client, a game console, a tablet, a personal digitalassistant (PDA), a smartphone, a digital music player having webinterface capabilities, and/or any other portable or stationarycomputing device.

The rendering module 234 in the external system(s) 230 can implementfunctionality for the graphical display and rendering of userinterfaces. It can, for example, generate graphical data thatcorresponds to an image class that represents graphical images processedby the client application 232; this graphical data can, potentiallyafter further modification and/or transformation by the operating systemof the external system(s) 230, be displayed on a display of thesystem(s) 230. Alternatively or additionally, when the externalsystem(s) 230 renders/displays image data, the rendering/displayingmodule 234 may perform functionality related to the rendering/display ofthe image data.

The networking module 236 can implement a communication protocol, and beused to handle various data messages between the external system(s) 230and, at least, the server system(s) 220. In one non-limiting example,the networking module 236 may carry out a socket connection by using asoftware connection class to initiate the socket connection betweendevices. Once the sockets are connected, networking module 236 maytransfer data to/from the server 220.

The software module 238 can be used to execute various code loaded atthe client application 232, and perform other functionality related tothe application software. The software module 238 may be, for example, aJava runtime engine or any other type of software module capable ofexecuting computer instructions developed using the Java programminglanguage. This example is of course non-limiting and the software module238 may execute computer instructions developed using any variety ofprogramming languages including, but not limited to, C, C++, C #,Python, JavaScript, or PHP. Alternatively or additionally, when theexternal system(s) 230 performs functionality related to the softwaremodule, such functionality may be handled by the software module 238.

It should be appreciated that the components shown in FIG. 2 can beimplemented within a single system. The components could also beincorporated in multiple systems and/or a distributed computingenvironment (e.g., a cloud computing environment). Thus, the system isnot limited to a single component and can be incorporated into multiplecomponents.

FIGS. 3A-3M show non-limiting example user interfaces 300 that areoperational with the methodology herein. In this regard, user interfaces300 show non-limiting implementations of search result arrangements thatcan be displayed to a human reviewer during a data file review.

FIG. 3A specifically shows summary items 301 of different PII elementsautomatically identified from a first data file collection. For example,user interface 300 can show summary items 301 indicating an overview ofdata files containing different PII elements identified from the firstdata file collection derived from the digital forensic analysis of adata breach event that can include, but are not limited to, one or morepersonal data elements, only contact information, non-contact PII dataelements, and name+PII data elements (with each summary item 301including an associated number with each of these categories).

FIGS. 3B and 3C show further example user interfaces 300 providingfurther detailed information that expands on the summary items 301. FIG.3B specifically shows an example user interface 300 containing uniquePII data elements 302 showing the unique pieces of information for eachdifferent PII. For example, unique PII data elements 302 may include anindication of 141 passport identification numbers found in the datafiles, while also showing an indication of 340 user PIN numbers found inthe data files in the automatic analysis of the first data filecollection. FIG. 3C shows a data file breakdown 303 of the data filescontaining PII data. For example, user interface 300 shown in FIG. 3Cmay indicate that 1912 data files contained PIN information, while alsoindicating that 978 data files included SSNs. These user interfaces 300advantageously give the human reviewer instant insight into the numberof affected data files and individuals within the data file set andallows them to generate insights about the size and scope of the databreach review process to, for example, generate a staffing plan for thereview and to predict the time needed to appropriately act oncompliance-related activities associated with the data breach event.

FIG. 3D shows another example user interface 300 including a filteringwindow 304 for filtering one or more data files for review. In onenon-limiting example, filtering window 304 may include a filtering pane305 allowing a user to filter data files by different elementsincorporated therein as determined by the automatic review of the firstdata file collection. For example, filtering pane 305 may includeoptions for filtering PII elements by category, by specific PIIelements, and/or file types, among others. Some of these aspects of theuser interface may be associated with a plurality of data analysismethodologies that are relevant in the context of the data file reviewas being conducted. For example, the human reviewer may be tasked withdetermining whether any of the data files contain personal informationassociated with a plurality of types of personal information that mightbe relevant to a plurality of applicable laws, regulations, policies,procedures, and contractual obligations for which compliance-relatedactivities need to be conducted as a result of the data breach event.

FIG. 3D shows an example where, as a human reviewer views data files,she may begin to formulate a review plan for the collection of data fileassigned to her. The human reviewer can filter in data files of interestto the one or more laws, regulations, policies, procedures, andcontractual obligations relevant to the data breach event, and removedata files that are not relevant.

FIG. 3E shows an example of a user interface where image data present inthe first data file collection is configured for display to the humanreviewer in a grid view format. In an implementation, interface 300configured as image gallery 306 can enable the human reviewer to scrollthrough the image gallery and select images that may comprise personaldata elements, whether in the form of PII or otherwise. The human reviewcan also classify one or more of the displayed images, and such humanreviewer action can be used as feedback to train machine learningsystems operational with the current data breach review project, as wellas in other data breach review projects.

FIG. 3F shows a further example user interface 300 containing a summaryview 307 which can include an “About Me” feature. In one non-limitingexample, the summary view 307 may include a text narrative describing anindividual/entity identified in the second data file collection togetherwith different information associated with the individual/entity. Thesummary view 307 may allow the human reviewer to individually selectdata elements (e.g., by selecting a “checkbox” item) where suchinformation may then be included in a profile window 308 for adding theinformation to an individual/entity profile. In the example shown inFIG. 3F, the selected information for “John Oswald” includes a SSN, DOB,and credit card number. This information may be added to thecompliance-related database for use in compliance-related activities asdiscussed elsewhere herein.

FIGS. 3G-3I show another non-limiting example user interfaces 300related to a feature that allows a plurality of information to bepopulated in a compliance-related database without human reviewer actionon each entry, which can enhance the speed and accuracy of databasepreparation when such data file types are part of the data filecollections. FIG. 3G specifically shows a user interface 300 including aspreadsheet view 309 that includes various columns for different fieldsassociated with different entries where each row includes the specificentries. In the example shown in FIG. 3G, fields “First Name,” “LastName,” “Email Address,” and “SSN” are depicted as columns in thespreadsheet view 309, where the associated elements are populated ineach of the individual rows.

FIG. 3H shows a non-limiting example user interface 300 after a humanreviewer selected a “map icon” in the interface 300 shown in FIG. 3G.FIG. 3H specifically shows a map view 310 where a human reviewer can mapdifferent fields from the spreadsheet view 309 to fields stored in acompliance-related database. In the example shown in FIG. 3G, the humanreviewer has selected “First Name” in the spreadsheet view 309 to map to“First Name” in the compliance-related database. Likewise, the humanreviewer has selected other various fields such as “Last Name,” “EmailAddress,” and “SSN” in the spreadsheet view 309 to fields of the samename in the compliance-related database.

FIG. 3I shows another non-limiting example user interface 300 when thefields have been mapped in the process shown in FIG. 3H. The userinterface 300 in FIG. 3I is similar to that shown in FIG. 3G, but nowthe entity list window 311 is populated with differententities/individuals mapped into the compliance-related database. Theentity list window 311 shows the entity first and last names and suchinformation can be expanded based on additional user input. It should beappreciated that an “ActiveLookahead” feature can take the informationentered by a human reviewer on one data file, and use it to look acrossall other data files in the data file set to see if that combination ofinformation appears in one or more other data files. If it does, therelevant information can be automatically extracted from the data fileand added to the database. This feature can substantially reduce themanual effort required by the human reviewer, as would be appreciated.

FIGS. 3J and 3K show further non-limiting example user interfaces 300for performing the “clean-up” process. FIG. 3J specifically shows anexpanded entity list window 312 showing different entities withassociated information. The expanded entity list window 312 couldcorrespond to entity list window 311 but with greater amounts ofinformation displayed. In the example shown in FIG. 3J, the expandedentity list window 312 shows records having possible related entities.Specifically, the example of FIG. 3J shows two records for “Amy Coleman”and “Amy Cohen,” respectively that appear to have the same SSN. Thesystem is configurable to merge these related records into a singlerecord (e.g., automatically or through human reviewer intervention).During the merge process, a human reviewer may select which informationto keep and/or discard in the merge process.

FIG. 3K shows an example user interface 300 where human reviewers canview further information of the related entities. For example, FIG. 3Kshows a related entities window 313 showing a specific entity as well asa record that may be related. In the example shown in FIG. 3K, thespecific entity is “Amy Coleman” while the related entity “Amy Cohen” isshown with corresponding details. The human reviewer may then decidewhether to merge and/or discard one or more related entities (as well asthe specific details for the related entity). The system can beconfigured with machine learning systems that learn from the humanreviewer selections in order to enhance the process for merging entitiesduring the current review, as well as that of other reviews fordifferent data breach event process.

FIG. 3L shows an example user interface 300 with an example situationfor anomaly detection. In the example of FIG. 3L, the expanded entitylist window 312 shows “April Smith” having two different SSNs. Thiscould indicate two individuals with the same name, or the sameindividual erroneously associated with a wrong SSN. Anomaly detectioncan “flag” this entity identification and provide a notification to thehuman reviewer of a recommended selection based on all the availableinformation. When the human reviewer makes a decision, the system canrecord that decision for future selection options. For example, if AprilSmith and April Myers are the same person, as determined by a humanreviewer, the system can remember that in future cases when the sameApril Smith and April Myers are found (based on the additionalidentifying information). For example, the system can be configured touse the previous human reviewer and system actions to determine whichlast name to keep among other information.

FIG. 3M shows a further example of user interface 300 having checklists314. For several of the checkboxes in checklists 314, the human reviewerdoes not select for storing the information as they would for a piece offielded information (e.g., shown on the rightmost image). When the humanreviewer selects these boxes, the provides the ability to learn whatinformation the human reviewer is interested in, upon which the systemcan then use within context to train various machine learning models todetect that additional information in the data file that has not yetbeen reviewed by a human reviewer.

FIG. 4 shows block diagram illustrating an example of a hardwarearchitecture for the system 1260. In the example shown in FIG. 4, theclient device 1210 communicates with a server system 1200 via a network1240. The network 1240 can comprise a network of interconnectedcomputing devices, such as the internet. The network 1240 can alsocomprise a local area network (LAN) or a peer-to-peer connection betweenthe client device 1210 and the server system 1200. The hardware elementsshown in FIG. 4 can be used to implement the various software componentsand actions shown and described above as being included in and/orexecuted at the client device 1210 and server system 1200.

In some implementations, the client device 1210 (which may also bereferred to as a “client system” herein) can include one or more of thefollowing: one or more processors 1212; one or more memory devices 1214;one or more network interface devices 1216; one or more displayinterfaces 1218; and one or more user input adapters 1220. Additionally,in some implementations, the client device 1210 can be connected to orincludes a display device 1222. These elements (e.g., the processors1212, memory devices 1214, network interface devices 1216, displayinterfaces 1218, user input adapters 1220, display device 1222) arehardware devices (for example, electronic circuits or combinations ofcircuits) that are configured to perform various different functions forthe computing device 1210.

In some implementations, each or any of the processors 1212 is orincludes, for example, a single- or multi-core processor, amicroprocessor (e.g., which may be referred to as a central processingunit or CPU), a digital signal processor (DSP), a microprocessor inassociation with a DSP core, an Application Specific Integrated Circuit(ASIC), a Field Programmable Gate Array (FPGA) circuit, or asystem-on-a-chip (SOC) (e.g., an integrated circuit that includes a CPUand other hardware components such as memory, networking interfaces, andthe like). And/or, in some implementations, each or any of theprocessors 1212 uses an instruction set architecture such as x86 orAdvanced RISC Machine (ARM).

In some implementations, each or any of the memory devices 1214 cancomprise a random access memory (RAM) (such as a Dynamic RAM (DRAM) orStatic RAM (SRAM)), a flash memory (based on, e.g., NAND or NORtechnology), a hard disk, a magneto-optical medium, an optical medium,cache memory, a register (e.g., that holds instructions), or other typeof device that performs the volatile or non-volatile storage of dataand/or instructions (e.g., software that is executed on or by processors1212). Memory devices 1214 are examples of non-volatilecomputer-readable storage media.

In some implementations, each or any of the network interface devices1216 includes one or more circuits (such as a baseband processor and/ora wired or wireless transceiver), and implements layer one, layer two,and/or higher layers for one or more wired communications technologies(such as Ethernet (IEEE 802.3)) and/or wireless communicationstechnologies (such as Bluetooth, WiFi (IEEE 802.11), GSM, CDMA2000,UMTS, LTE, LTE-Advanced (LTE-A), and/or other short-range, mid-range,and/or long-range wireless communications technologies). Transceiversmay comprise circuitry for a transmitter and a receiver. The transmitterand receiver may share a common housing and may share some or all of thecircuitry in the housing to perform transmission and reception. In someimplementations, the transmitter and receiver of a transceiver may notshare any common circuitry and/or may be in the same or separatehousings.

In some implementations, each or any of the display interfaces 1218 cancomprise one or more circuits that receive data from the processors 1212or processing circuitry, generate (e.g., via a discrete GPU, anintegrated GPU, a CPU executing graphical processing, or the like)corresponding image data based on the received data, and/or output(e.g., a High-Definition Multimedia Interface (HDMI), a DisplayPortInterface, a Video Graphics Array (VGA) interface, a Digital VideoInterface (DVI), or the like), the generated image data to the displaydevice 1222, which displays the image data. Alternatively oradditionally, in some implementations, each or any of the displayinterfaces 1218 can comprise, for example, a video card, video adapter,or graphics processing unit (GPU).

In some implementations, each or any of the user input adapters 1220 isor includes one or more circuits that receive and process user inputdata from one or more user input devices (not shown in FIG. 4) that areincluded in, attached to, or otherwise in communication with the clientdevice 1210, and that output data based on the received input data tothe processors 1212. Alternatively or additionally, in someimplementations each or any of the user input adapters 1220 is orincludes, for example, a PS/2 interface, a USB interface, a touchscreencontroller, or the like; and/or the user input adapters 1220 facilitatesinput from user input devices (not shown in FIG. 7) such as, forexample, a keyboard, mouse, trackpad, touchscreen, etc.

In some implementations, the display device 1222 may be a Liquid CrystalDisplay (LCD) display, Light Emitting Diode (LED) display, or other typeof display device. In implementations where the display device 1222 is acomponent of the client device 1210 (e.g., the computing device and thedisplay device are included in a unified housing), the display device1222 may be a touchscreen display or non-touchscreen display. Inimplementations where the display device 1222 is connected to the clientdevice 1210 (e.g., is external to the client device 1210 andcommunicates with the client device 1210 via a wire and/or via wirelesscommunication technology), the display device 1222 can be, for example,an external monitor, projector, television, display screen, etc.

In various implementations, the client device 1210 includes one, or two,or three, four, or more of each or any of the above-mentioned elements(e.g., the processors 1212, memory devices 1214, network interfacedevices 1216, display interfaces 1218, and user input adapters 1220).Alternatively or additionally, in some implementations, the clientdevice 1210 includes one or more of: a processing system that includesthe processors 1212; a memory or storage system that includes the memorydevices 1214; and a network interface system that includes the networkinterface devices 1216.

The client device 1210 may be arranged, in various implementations, inmany different ways. As just one example, the client device 1210 may bearranged such that the processors 1212 include: a multi (or single)-coreprocessor; a first network interface device (which implements, forexample, WiFi, Bluetooth, NFC, etc.); a second network interface devicethat implements one or more cellular communication technologies (e.g.,3G, 4G LTE, CDMA, etc.); memory or storage devices (e.g., RAM, flashmemory, or a hard disk). The processor, the first network interfacedevice, the second network interface device, and the memory devices maybe integrated as part of the same SOC (e.g., one integrated circuitchip). As another example, the client device 1210 may be arranged suchthat: the processors 1212 include two, three, four, five, or moremulti-core processors; the network interface devices 1216 include afirst network interface device that implements Ethernet and a secondnetwork interface device that implements WiFi and/or Bluetooth; and thememory devices 1214 include a RAM and a flash memory or hard disk.

Server system 1200 also comprises various hardware components used toimplement the software elements for server system 200 of FIG. 2. In someimplementations, the server system 1200 (which may also be referred toas “server device” herein) includes one or more of the following: one ormore processors 1202; one or more memory devices 1204; and one or morenetwork interface devices 1206. These elements (e.g., the processors1202, memory devices 1204, network interface devices 1206) are hardwaredevices (for example, electronic circuits or combinations of circuits)that are configured to perform various different functions for theserver system 1200. In other implementations, the server system 1200 cancomprise one or more computers or other computing devices.

In some implementations, each or any of the processors 1202 cancomprise, for example, a single- or multi-core processor, amicroprocessor (e.g., which may be referred to as a central processingunit or CPU), a digital signal processor (DSP), a microprocessor inassociation with a DSP core, an Application Specific Integrated Circuit(ASIC), a Field Programmable Gate Array (FPGA) circuit, or asystem-on-a-chip (SOC) (e.g., an integrated circuit that includes a CPUand other hardware components such as memory, networking interfaces, andthe like). And/or, in some implementations, each or any of theprocessors 1202 uses an instruction set architecture such as x86 orAdvanced RISC Machine (ARM).

In some implementations, each or any of the memory devices 1204 cancomprise a random access memory (RAM) (such as a Dynamic RAM (DRAM) orStatic RAM (SRAM)), a flash memory (based on, e.g., NAND or NORtechnology), a hard disk, a magneto-optical medium, an optical medium,cache memory, a register (e.g., that holds instructions), or other typeof device that performs the volatile or non-volatile storage of dataand/or instructions (e.g., software that is executed on or by processors1202). Memory devices 1204 are examples of non-volatilecomputer-readable storage media.

In some implementations, each or any of the network interface devices1206 includes one or more circuits (such as a baseband processor and/ora wired or wireless transceiver), and implements layer one, layer two,and/or higher layers for one or more wired communications technologies(such as Ethernet (IEEE 802.3)) and/or wireless communicationstechnologies (such as Bluetooth, WiFi (IEEE 802.11), GSM, CDMA2000,UMTS, LTE, LTE-Advanced (LTE-A), and/or other short-range, mid-range,and/or long-range wireless communications technologies). Transceiversmay comprise circuitry for a transmitter and a receiver. The transmitterand receiver may share a common housing and may share some or all of thecircuitry in the housing to perform transmission and reception. In someimplementations, the transmitter and receiver of a transceiver may notshare any common circuitry and/or may be in the same or separatehousings.

In various implementations, the server system 1200 includes one, or two,or three, four, or more of each or any of the above-mentioned elements(e.g., the processors 1202, memory devices 1204, network interfacedevices 1206). Alternatively or additionally, in some implementations,the server system 1200 includes one or more of a processing system thatincludes the processors 1202; a memory or storage system that includesthe memory devices 1204; and a network interface system that includesthe network interface devices 1206.

The server system 1200 may be arranged, in various implementations, inmany different ways. As just one example, the server system 1200 may bearranged such that the processors 1202 include: a multi (or single)-coreprocessor; a first network interface device (which implements, forexample, WiFi, Bluetooth, NFC, etc.); a second network interface devicethat implements one or more cellular communication technologies (e.g.,3G, 4G LTE, CDMA, etc.); memory or storage devices (e.g., RAM, flashmemory, or a hard disk). The processor, the first network interfacedevice, the second network interface device, and the memory devices maybe integrated as part of the same SOC (e.g., one integrated circuitchip). As another example, the server system 1200 may be arranged suchthat: the processors 1202 include two, three, four, five, or moremulti-core processors; the network interface devices 1206 include afirst network interface device that implements Ethernet and a secondnetwork interface device that implements WiFi and/or Bluetooth; and thememory devices 1204 include a RAM and a flash memory or hard disk.

It should be noted that, when a software module, application or softwareprocess performs any action, the action is in actuality performed byunderlying hardware elements according to the instructions that comprisethe software module. Consistent with the foregoing, in variousimplementations, each or any combination of the client device 1210 orthe server system 1200, each of which will be referred to individuallyfor clarity as a “component” for the remainder of this paragraph, areimplemented using an example of the client device 1210 or the serversystem 1200 of FIG. 4. In such implementations, the following appliesfor each component (a) the elements of the client device 1210 shown inFIG. 4 (i.e., the one or more processors 1212, one or more memorydevices 1214, one or more network interface devices 1216, one or moredisplay interfaces 1218, and one or more user input adapters 1220) andthe elements of the server system 1200 (i.e., the one or more processors1202, one or more memory devices 1204, one or more network interfacedevices 1206), or appropriate combinations or subsets of the foregoing,are configured to, adapted to, and/or programmed to implement each orany combination of the actions, activities, or features described hereinas performed by the component and/or by any software modules describedherein as included within the component; (b) alternatively oradditionally, to the extent it is described herein that one or moreapplications or software modules exist within the component, in someimplementations, such applications or software modules (as well as anydata described herein as handled and/or used by the applications orsoftware modules) can be stored in the respective memory devices (e.g.,in various implementations, in a volatile memory device such as a RAM oran instruction register and/or in a non-volatile memory device such as aflash memory or hard disk) and all actions described herein as performedby the software modules are performed by the respective processors inconjunction with, as appropriate, the other elements in and/or connectedto the client device 1210 or server system 1200; (c) alternatively oradditionally, to the extent it is described herein that the componentprocesses and/or otherwise handles data, in some implementations, suchdata can be stored in the respective memory devices (e.g., in someimplementations, in a volatile memory device such as a RAM and/or in anon-volatile memory device such as a flash memory or hard disk) and/oris processed/handled by the respective processors in conjunction, asappropriate, the other elements in and/or connected to the client device1210 or server system 1200; (d) alternatively or additionally, in someimplementations, the respective memory devices store instructions that,when executed by the respective processors, cause the processors toperform, in conjunction with, as appropriate, the other elements inand/or connected to the client device 1210 or server system 1200, eachor any combination of actions described herein as performed by thecomponent and/or by any software modules described herein as includedwithin the component.

Any logic, application or software module described herein thatcomprises software or instructions can be embodied in any non-transitorycomputer-readable medium for use by or in connection with an instructionexecution system such as, for example, a processor 1202 in a computersystem or other system. In this sense, the logic may comprise, forexample, statements including instructions and declarations that can befetched from the computer-readable medium and executed by theinstruction execution system. The flowcharts or diagrams of FIGS. 1A and1B show examples of the architecture, functionality, and operation ofpossible implementations of an information extraction and analysisapplication. In this regard, each block can represent a module, segment,or portion of code, which comprises one or more executable instructionsfor implementing the specified logical function(s). It should also benoted that in some alternative implementations, the functions noted inthe blocks may occur out of the order noted in FIGS. 1A and 1B. Forexample, two blocks shown in succession in FIGS. 1A and 1B may in factbe executed substantially concurrently or the blocks may sometimes beexecuted in a different or reverse order, depending upon thefunctionality involved. Alternate implementations are included withinthe scope of the preferred implementation of the present disclosure inwhich functions may be executed out of order from that shown ordiscussed, including substantially concurrently or in reverse order,depending on the functionality involved, as would be understood by thosereasonably skilled in the art of the present disclosure.

The hardware configurations shown in FIG. 4 and described above areprovided as examples, and the subject matter described herein may beutilized in conjunction with a variety of different hardwarearchitectures and elements. For example: in many of the Figures in thisdocument, individual functional/action blocks are shown; in variousimplementations, the functions of those blocks may be implemented using(a) individual hardware circuits, (b) using an application specificintegrated circuit (ASIC) specifically configured to perform thedescribed functions/actions, (c) using one or more digital signalprocessors (DSPs) specifically configured to perform the describedfunctions/actions, (d) using the hardware configuration described abovewith reference to FIG. 4, (e) via other hardware arrangements,architectures, and configurations, and/or via combinations of thetechnology described in (a) through (e).

As described herein, the exemplary aspects have been described andillustrated in the drawings and the specification. The exemplary aspectswere chosen and described in order to explain certain principles of theinvention and their practical application, to thereby enable othersskilled in the art to make and utilize various exemplary aspects of thepresent invention, as well as various alternatives and modificationsthereof. As is evident from the foregoing description, certain aspectsof the present invention are not limited by the particular details ofthe examples illustrated herein, and it is therefore contemplated thatother modifications and applications, or equivalents thereof, will occurto those skilled in the art. Many changes, modifications, variations andother uses and applications of the present construction will, however,become apparent to those skilled in the art after considering thespecification and the accompanying drawings. All such changes,modifications, variations and other uses and applications which do notdepart from the spirit and scope of the invention are deemed to becovered by the invention which is limited only by the claims whichfollow.

What is claimed is:
 1. A method of managing compliance-relatedactivities after a data breach associated with an enterprise IT networkcomprising: a. receiving, by at least one computer, a first data filecollection associated with a first data breach event wherein: i. thefirst data file collection is:
 1. generated by analysis of the firstdata breach event and derived from a bulk data file collection stored onor associated with a first enterprise IT network of interest formonitoring for an occurrence of data breach events; ii. the first datafile collection comprises at least some of structured, unstructured, andsemi-structured data file types; and iii. at least some of the firstdata file collection comprises protected information havingcompliance-related activities associated therewith; b. generating, bythe at least one computer, information associated with presence orabsence of protected information elements of all or part of the firstdata file collection and, if the generated information indicates that adata file in the first data file collection includes the protectedinformation elements, incorporating that data file in a second data filecollection; c. analyzing, by at least one human reviewer, a subset ofindividual data files selected from the second data file collection tovalidate that each data file in the subset of individual data filescomprises one or more of the protected information elements, wherein: i.if it is determined that the one or more protected information elementsare not present in a data file, removing, by the at least one humanreviewer, that data file from the second data file collection andre-incorporating that data file into the first data file collection; orii. if it is determined that the one or more protected informationelements are present in a data file:
 1. deriving, by either or both ofthe at least one human reviewer or the at least one computer, at leastone entity identification for an entity associated with each of the oneor more protected information elements in that data file, wherein theentity comprises an individual, a group of individuals, an organization,or a company; and
 2. generating, by either or both of the at least onehuman reviewer or the at least one computer, information associated witheach of the one or more protected information elements and theassociated entity; and d. incorporating, by the at least one computer,the information associated with the analysis of the subset of individualdata files into machine learning information configured for subsequentanalysis of either or both of the first and second data filecollections.
 2. The method of claim 1, wherein the unstructured datafile type in the first data file collection comprises image files. 3.The method of claim 2, further comprising: a. selecting, by the at leastone computer, a subset of image files from either or both of the firstand second data file collections; b. configuring, by the at least onecomputer, the subset of image files for display and selection on a userdevice associated with the at least one human reviewer; c. displaying,by the at least one computer, a plurality of the image files from thesubset of image files on the user device; d. selecting, by the at leastone human reviewer, a displayed image when the at least one humanreviewer identifies that the displayed image is associated with the oneor more protected information elements; and e. recording, by the atleast one computer, information associated with the at least one humanreviewer's selection of the displayed image, thereby providingidentification information for the presence or absence of the one ormore protected information elements in at least some image files in thesubset of image files selected from either or both of the first andsecond data file collections.
 4. The method of claim 3, furthercomprising: a. incorporating, by the at least one computer, theidentification information into machine learning training information;and b. analyzing, by the at least one computer, image files in the firstand second data file collections for the presence of the one or moreprotected information elements.
 5. The method of claim 3, furthercomprising: a. identifying, by the at least one computer, some or all ofthe one or more protected information elements and the at least oneentity identification in the image files; and b. extracting, by the atleast one computer, the identified protected information elements andthe at least one entity identification from the image files forincorporation in a database.
 6. The method of claim 1, furthercomprising: a. recording, by the at least one computer, informationassociated with the analysis by the at least one human reviewer of eachof the subset of individual data files in the second collection of datafiles; and b. incorporating, by the at least one computer, the at leastone human reviewer's analysis information as training information foruse in subsequent analysis of one or more of: i. data files in the firstdata file collection; ii. data files in the second data file collectionthat are not included in the subset of individual data files; iii. datafiles in the subset of individual data files that have not yet beenreviewed by the at least one human reviewer; iv. a third data filecollection derived from a bulk data file collection stored on orassociated with the first enterprise IT network, wherein the third datafile collection is generated after a second data breach event associatedwith the first enterprise IT network; or v. a fourth data filecollection derived from a bulk data file collection stored on orassociated with a second enterprise IT network that is different fromthe first enterprise IT network, wherein the fourth data file collectionis generated after a data breach event occurring on the secondenterprise IT network.
 7. The method of claim 1, further comprising: a.determining, by the at least one computer, whether one or more secondcollection data files of the second data file collection are associatedwith the at least one identified entity and, if other second collectiondata files are associated with that identified entity, generatinglinkages between the entity-associated files, thereby providing a linkeddata file collection linked with one or more entity identificationshaving the one or more protected information elements associatedtherewith.
 8. The method of claim 1, wherein each of the second datafile collection is arranged for display and selection on a displaydevice associated with the at least one human reviewer as one or moreof: a. a plurality of defined categories of the protected informationelements; b. a count of data files comprising the protected informationelements; and c. a count of data file categories comprising theprotected information elements.
 9. The method of claim 1, furthercomprising: a. displaying, by the at least one computer, text summariesextracted from a data file in the second data file collection on adevice display of the at least one human reviewer, wherein: i. thedisplayed text summaries comprise each of a protected informationelement and an entity identification in the data file; ii. the textsummaries are each provided on the display with highlighting generatedby the at least one computer; and iii. the text summaries are configuredto allow the at least one human reviewer to select all or part of eachof the protected information element and entity identification; b.selecting, by the at least one human reviewer, some or all of thehighlighted protected information elements and entity identifications,thereby providing human reviewer validation of the protected informationelements and entity identifications in the data file; and c. adding, bythe at least one computer, the selected protected information elementsand entity identifications to the database.
 10. The method of claim 1,wherein when the second data file collection is identified by either orboth of the at least one human reviewer or the at least one computer ascomprising a plurality of protected information elements associated withone or more entity identifications, each of the plurality of protectedinformation elements is linked to each of the one more entityidentifications.
 11. The method of claim 1, wherein the second data filecollection comprises an unstructured data file and the plurality ofprotected information data elements associated with the one or moreentity identifications are included as tabular data in the unstructureddata file.
 12. The method of claim 1, wherein the identification ofprotected information in the first data file collection is associatedwith a generated confidence level, and wherein when a determination thata data file in the first data file collection meets or exceeds thegenerated confidence level, that data file is included in the seconddata file collection.
 13. The method of claim 1, wherein thecompliance-related activities are defined by one or more of laws,regulations, policies, procedures, and contractual obligationsassociated with the protected information.
 14. The method of claim 13,wherein the compliance-related activities comprise one or more of: a.notifying, by the at least one computer or by a manager of the firstenterprise IT network, each identified entity of the protectedinformation associated with that entity that was involved with the firstdata breach event; and b. notifying, by the at least one computer or thefirst enterprise IT network manager, a regulatory authority of the firstnetwork breach event and providing the regulatory authority withinformation associated with the identified entities having the protectedinformation involved in the first data breach event.
 15. A method ofmanaging compliance-related activities after a data breach associatedwith an enterprise IT network comprising: a. providing, by at least onecomputer, a machine learning library generated by the method of: i.receiving, by the at least one computer, a first data file collectionassociated with a first data breach event wherein:
 1. the first datafile collection is: a. generated by analysis of the first data breachevent and derived from a bulk data file collection stored on orassociated with a first enterprise IT network of interest for monitoringfor an occurrence of data breach events; b. the first data filecollection comprises at least some of structured, unstructured, andsemi-structured data file types; and c. at least some of the first datafile collection comprises protected information havingcompliance-related activities associated therewith; ii. generating, bythe at least one computer, information associated with presence orabsence of protected information elements of all or part of the firstdata file collection and, if the generated information indicates that adata file in the first data file collection includes the protectedinformation elements, incorporating that data file in a second data filecollection; iii. analyzing, by at least one human reviewer, a subset ofindividual data files selected from the second data file collection tovalidate that each data file in the subset of individual data filescomprises one or more of the protected information elements, wherein: 1.if it is determined that the one or more protected information elementsare not present in a data file, removing, by the at least one humanreviewer, that data file from the second data file collection andre-incorporating that data file into the first data file collection; or2. if it is determined that the one or more protected informationelements are present in a data file: a. deriving, by either or both ofthe at least one human reviewer or the at least one computer, at leastone entity identification for an entity associated with each of the oneor more protected information elements in that data file, wherein theentity comprises an individual, a group of individuals, an organization,or a company; and b. generating, by either or both of the at least onehuman reviewer or the at least one computer, information associated witheach of the one or more protected information elements and theassociated entity; and iv. incorporating, by the at least one computer,the information associated with the analysis of the subset of individualdata files into machine learning information configured for subsequentanalysis of either or both of the first and second data filecollections, the machine learning information stored in the machinelearning library; b. receiving, by at least one computer, a third datafile collection associated with a second data breach event; and c.analyzing, by the at least one computer, the data files in the thirddata file collection to generate a compliance-related databaseconfigured for providing notifications associated with the second databreach event.
 16. The method of claim 15, further comprising: a.incorporating at least some human reviewer analysis with the third datafile collection analysis.
 17. The method of claim 15, wherein the thirddata file collection analysis includes identification of the presence orabsence of protected information elements in the data files.
 18. Themethod of claim 17, wherein at least some of the data files in the thirddata file collection comprise one or more protected informationelements, and the method further comprises: a. linking, by the at leastone computer, some or all of the one or more protected informationelements with at least one entity, thereby generating entityidentification information linkage information for at least some of theprotected information elements in the data files.
 19. The method ofclaim 18, wherein at least some of the data file types in the third datafile collection comprise image files.
 20. The method of claim 15,wherein the third data file collection comprises at least someunstructured data files and a plurality of protected informationelements associated with the one or more entity identifications areincluded as tabular data in the unstructured data file.
 21. The methodof claim 15, wherein the compliance-related activities are defined byone or more of laws, regulations, policies, procedures, and contractualobligations associated with the protected information.